ULNRC-06057, Enclosure 2 to ULNRC-06057 - Amendment 28 LRA Change for LRA Annual Update and RAI Set 28

Enclosure 2 to ULNRC-06057 - Amendment 28 LRA Change for LRA Annual Update and RAI Set 28

ML13360A274
Person / Time
Site:	Callaway
Issue date:	12/20/2013
From:	Ameren Missouri, Union Electric Co
To:	Office of Nuclear Reactor Regulation, NRC Region 4
References
ULNRC-06057
Download: ML13360A274 (136)

Text

ULNRC-06057 December 20, 2013 Page 1 of 136 Amendment 28 LRA Changes for LRA Annual Update and RAI Set 28 Enclosure 2 Summary Table Affected LRA Section LRA As-Submitted Page Number(s)

Table 2.1-2 2.1-22 Section 2.1.5.5 and Section 2.1.5.8 2.1-23 Section 3.2.2.1 3.2-2 through 3.2-8 Section 3.2.2.2.9 3.2-10 Table 3.2-1 3.2-33 Table 3.2.2-2 3.2-38 Table 3.2.2-4 3.2-48 Table 3.2.2-5 3.2-59, 3.2-63, and 3.2-66 Table 3.2.2-6 3.2-72 Section 3.3.2.1 3.3-4 through 3.4-35 Section 3.3.2.2.8 3.3-36 Table 3.3-1 3.3-51, 3.3-58 through 3.3-60, 3.3-66, and 3.3-81 Table 3.3.2-2 3.3-88 and 3.3-89 Table 3.3.2-4 3.3-94, 3.3-97 through 3.3-98 Table 3.3.2-5 3.3-100 through 3.3-104 Table 3.3.2-7 3.3-108 through 3.3-112 Table 3.3.2-10 3.3-131, 3.3-137 through 3.3-139, 3.3-146, 3.3-147 Table 3.3.2-11 3.3-149, 3.3-153 thru 3.3-158, and 3.3-160 Table 3.3.2-13 3.3-168 Table 3.3.2-14 3.3-177 Table 3.3.2-15 3.3-186 Table 3.3.2-19 3.3-201 Table 3.3.2-20 3.3-204, 3.3-216 Table 3.3.2-21 3.3-219, and 3.3-221 Table 3.3.2-22 3.3-228 Table 3.3.2-26 3.3-259, 3.3-260, and 3.3-262 Table 3.3.2-27 3.3-267 Table 3.3.2-28 3.3-273, and 3.3-275 Section 3.4.2.1 3.4-2 thru 3.4-9 Section 3.4.2.2.6 3.4-10 Table 3.4-1 3.4-15, 3.4-16, 3.4-21, 3.4-22, and 3.4-31 Table 3.4.2-2 3.4-34, and 3.4-40 Table 3.4.2-3 3.4-42, and 3.4-46 Table 3.4.2-5 3.4-54, and 3.4-60

ULNRC-06057 December 20, 2013 Page 2 of 136 Table 3.4.2-6 3.4-62, 3.4-63 and 3.4-65 Table 4.3-3 4.3-19 and 4.3-22 Section A1.6 A-4 Section A1.10 A-6, and A-7 Section A1.14 A-8 Section A1.15 A-8 and A-9 Section A1.21 A-12 Section A1.23 A-13 Table A4-1 item 4 A-37 Table A4-1 item 6 A-37 Table A4-1 item 9 A-38 Table A4-1 item 10 A-38, and A-39 Table A4-1 item 13 A-40 Table A4-1 item 17 A-41 Table A4-1 item 33 A-47 Table A4-1 item 34 A-48 Table A4-1 item 35 A-48 and A-49 Table A4-1 item 41 A-49 Table A4-1 item 42 A-49 Section B2.1.6 B-28, B-29, and B-30 Section B2.1.10 B-41, B-42, B-43, and B-44 Section B2.1.13 B-50, B-51, and B-52 Section B2.1.14 B-53, B-54, B-55, and B-56 Section B2.1.15 B-57, B-58, and B-59 Section B2.1.17 B-64 and B-65 Section B2.1.21 B-75, B-76, B-77, and B-78 Section B2.1.23 B-81, B-82, and B-83

ULNRC-06057 December 20, 2013 Page 3 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to update Table 2.1-2 to update the status of LR-ISG-2011-04 and add LR-ISG-2012-02.

Table 2.1-2 (Page 2.1-22) is revised as follows (new text shown underlined and deleted text shown in strikethrough):

Table 2.1-2 NRC Interim Staff Guidance Associated with License Renewal Issue Number Purpose Discussion Status LR-ISG-2006-03 Staff Guidance for Preparing The staff has issued LR-ISG-2006-03.

Severe Accident Mitigation Alternatives (SAMA) Analyses LR-ISG-2011-01 Aging Management of Stainless The staff has issued LR-ISG-2011-01.

Steel Structures and Components in Treated Borated Water LR-ISG-2011-02 Aging Management Program for The staff has issued LR-ISG-2011-02.

Steam Generators LR-ISG-2011-03 Aging Management Program for The staff has issued LR-ISG-2011-03.

Buried and Underground Piping and Tanks LR-ISG-2011-04 Updated Aging Management This ISG has been issued in draft for Criteria for Reactor Vessel public comment. The staff has issued LR-Internal Components of ISG-2011-04 Pressurized Water Reactors LR-ISG-2011-05 Ongoing Review of Operating The staff has issued LR-ISG-2011-05.

Experience LR-ISG-2012-01 Wall Thinning Due to Erosion The staff has issued LR-ISG-2012-01.

Mechanisms LR-ISG-2012-02 Aging Management of Internal The staff has issued LR-ISG-2012-02.

Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation

ULNRC-06057 December 20, 2013 Enclosure 2 Page 4 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to update Section 2.1.5.5 on LR-ISG-2011-04 and add Section 2.1.5.8 on LR-ISG-2012-02.

Section 2.1.5.5 (Page 2.1-23) and Section 2.1.5.8 (Page 2.1-23) are revised as follows (new text shown underlined and deleted text shown in strikethrough):

2.1.5.5. (LR-ISG-2011-04) Updated Aging Management Criteria for Reactor Vessel Internal Components of Pressurized Water Reactors This LR-ISG was issued in draft as final and is applicable to Callaway. The aging management program for the reactor vessel internal components is discussed in Section B2.1.6, PWR Vessel Internals. Results are provided in Chapter 3, Aging Management Review.

2.1.5.8. (LR-ISG-2012-02) Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation This LR-ISG was issued as final and is applicable to Callaway. The applicable aging management programs are discussed in Section B2.1.10, Open-Cycle Cooling Water System, Section B2.1.14, Fire Water System, Section B2.1.15, Aboveground Metallic Tanks, Section B2.1.21, External Surfaces Monitoring of Mechanical Components, and Section B2.1.23, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Systems.

ULNRC-06057 December 20, 2013 Page 5 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to Section 3.2.2.1, Materials, Environments, Aging Effects Requiring Management and Aging Management Programs (AMPs), as a result of LR-ISG-2012-02 changes.

Section 3.2.2.1 in Chapter V of NUREG-1801 for Engineered Safety Features, (Page 3.2-2 thru 3.2-8) is revised to add the materials, environments, aging effects requiring management and (AMPs) to the sections indicated.

3.2.2.1 Materials, Environments, Aging Effects Requiring Management and Aging Management Programs (AMPs)

Loss of Material and Cracking 3.2.2.1.4 Containment Purge System 3.2.2.1.5 High Pressure Coolant Injection System Reduced Thermal Insulation Resistance 3.2.2.1.6 Residual Heat Removal system

ULNRC-06057 December 20, 2013 Page 6 of 136 Callaway Plant License Renewal Application Amendment 28 Add a new section for the further evaluation for loss of material due to recurring internal corrosion.

Further Evaluation 3.2.2.2.9 (Page 3.2-10) is added as follows (new text shown underlined):

3.2.2.2.9 Loss of Material Due to Recurring Internal Corrosion Operating experience associated with Engineered Safety Features Systems and associated aging management programs does not meet the threshold for significance of aging effect or frequency of occurrence of the aging effect to be considered as recurring internal corrosion.

ULNRC-06057 December 20, 2013 Page 7 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to corporate aging management of the refueling water storage tanks by the Aboveground Metallic tanks program.

Table 3.2-1, Summary of Aging Management Programs in Chapter V of NUREG-1801 for Engineered Safety Features, (Page 3.2-33) is revised as follows (new text underlined and deleted text shown in strikethrough):

Table 3.2-1 Summary of Aging Management Programs in Chapter V of NUREG-1801 for Engineered Safety Features Item Component Type Aging Effect / Mechanism Aging Management Further Evaluation Discussion Number Program Recommended 3.2.1.066 Metallic piping, Loss of material due to A plant-specific aging Yes, plant-specific Not applicable. Callaway has no piping components, recurring internal corrosion management program is (See Subsection in-scope components subject to and tanks exposed to be evaluated to 3.2.2.2.9) recurring internal corrosion in the to raw water or address recurring engineered safety features, so waste water internal corrosion the applicable NUREG-1801 lines were not used.

3.2.1.067 Stainless steel or Cracking due to stress Aboveground Metallic No Not applicable. Callaway has no aluminum tanks corrosion cracking Tanks (B2.1.15) in-scope uninsulated stainless (within the scope of steel or aluminum tanks greater Chapter XI.M29, than 100,000 gallons exposed to Aboveground soil, concrete, or external Metallic Tanks) environments engineered safety exposed to soil or features, so the applicable concrete, or the NUREG-1801 lines were not following external used.

environments air-outdoor, air-indoor uncontrolled, moist air, condensation

ULNRC-06057 December 20, 2013 Page 8 of 136 Table 3.2-1 Summary of Aging Management Programs in Chapter V of NUREG-1801 for Engineered Safety Features Item Component Type Aging Effect / Mechanism Aging Management Further Evaluation Discussion Number Program Recommended 3.2.1.068 Steel, stainless Loss of material due to Aboveground Metallic No Not applicable. Callaway has no steel, or aluminum general (steel only), pitting, Tanks (B2.1.15) in-scope uninsulated steel, tanks (within the and crevice corrosion stainless steel or aluminum tanks scope of Chapter greater than 100,000 gallons XI.M29, exposed to soil, concrete, or Aboveground external environments Metallic Tanks) engineered safety features, so exposed to soil or the applicable NUREG-1801 concrete, or the lines were not used.

following external environments air-outdoor, air-indoor uncontrolled, moist air, condensation 3.2.1.069 Insulated steel, Loss of material due to External Surfaces No Consistent with NUREG-1801.

stainless steel, general (steel, and copper Monitoring of Mechanical copper alloy, or alloy only), pitting, and Components (B2.1.21) or aluminum, piping, crevice corrosion Aboveground Metallic piping components, Tanks (B2.1.15) (for and tanks exposed tanks only) to condensation, air-outdoor

ULNRC-06057 December 20, 2013 Page 9 of 136 Table 3.2-1 Summary of Aging Management Programs in Chapter V of NUREG-1801 for Engineered Safety Features Item Component Type Aging Effect / Mechanism Aging Management Further Evaluation Discussion Number Program Recommended 3.2.1.070 Steel, stainless steel Loss of material due to Aboveground Metallic No Consistent with NUREG-1801.

or aluminum tanks general (steel only), pitting Tanks (B2.1.15)

(within the scope of and crevice corrosion Chapter XI.M29, Aboveground Metallic Tanks) exposed to treated water, treated borated water 3.2.1.071 Insulated stainless Cracking due to stress External Surfaces No Consistent with NUREG-1801.

steel, aluminum, or corrosion cracking Monitoring of Mechanical copper alloy (> 15% Components (B2.1.21) or Zn) piping, piping Aboveground Metallic components, and Tanks (B2.1.15) (for tanks exposed to tanks only) condensation, air-outdoor

ULNRC-06057 December 20, 2013 Page 10 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to add LR-ISG-2012-02 aging evaluation lines for insulated piping Table 3.2.2-2 (Page 3.2-38) is revised as follows (new text shown underlined):

Table 3.2.2-2 Engineered Safety Features - Summary of Aging Management Evaluation - Containment Integrated Leak Rate Testing System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping LBS Carbon Steel Condensation Loss of External Surfaces V.C.E-403 3.2.1.069 A (Ext) material Monitoring of Mechanical Components (B2.1.21)

ULNRC-06057 December 20, 2013 Page 11 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to add LR-ISG-2012-02 aging evaluation lines for insulated piping.

Table 3.2.2-4 (Page 3.2-48) is revised as follows (new text shown underlined):

Table 3.2.2-4 Engineered Safety Features - Summary of Aging Management Evaluation - Containment Purge System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping LBS Carbon Steel Condensation Loss of External Surfaces VII.F3.A-405 3.3.1.132 A (Ext) material and Monitoring of Mechanical cracking Components (B2.1.21)

ULNRC-06057 December 20, 2013 Page 12 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to add LR-ISG-2012-02 aging evaluation lines for insulated piping and tanks Table 3.2.2-5 (Page 3.2-59, 3.2-63, and 3.2-66) is revised as follows (deleted text shown in strikethrough and new text shown underlined):

Table 3.2.2-5 Engineered Safety Features - Summary of Aging Management Evaluation - High Pressure Coolant Injection System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping PB, LBS, Stainless Condensation Cracking External Surfaces V.D1.E-406 3.2.1.071 A SIA Steel (Ext) Monitoring of Mechanical Components (B2.1.21)

Piping PB, LBS, Stainless Condensation Loss of External Surfaces V.D1.E-403 3.2.1.069 A SIA Steel (Ext) Material Monitoring of Mechanical Components (B2.1.21)

ULNRC-06057 December 20, 2013 Page 13 of 136 Table 3.2.2-5 Engineered Safety Features - Summary of Aging Management Evaluation - High Pressure Coolant Injection System (cont.)

Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Tank PB Stainless Atmosphere/ Cracking Loss Aboveground Metallic V.D1.EP-103 3.2.1.007 E, 1 Steel Weather (Ext) of material and Tanks (B2.1.15) VIII.E.SP-138 3.4.1.030 A Cracking Tank PB Stainless Atmosphere/ Loss of Aboveground Metallic V.D.EP-107 3.2.1.004 E, 1 Steel Weather (Ext) material Tanks (B2.1.15)

Tank PB Stainless Concrete (Ext) Loss of Aboveground Metallic VIII.E.SP-137 3.4.1.031 B Steel material and Tanks (B2.1.15) A Cracking Tank PB Stainless Condensation Loss of Inspection of Internal V.D1.EP-81 3.2.1.048 D Steel (Int) material Surfaces in Miscellaneous Piping and Ducting Components (B2.1.23)

Tank PB Stainless Treated Cracking Water Chemistry (B2.1.2) V.A.E-12 3.2.1.020 A Steel Borated Water and One-Time Inspection (Int) (B2.1.18)

Tank PB Stainless Treated Borated Loss of Water Chemistry (B2.1.2) VD.1.EP-41 3.2.1.022 A Steel Water (Int) material and One-Time Inspection V.D.1.E-404 3.2.1.070 (B2.1.18) Aboveground Metallic Tanks (B2.1.15)

ULNRC-06057 December 20, 2013 Page 14 of 136 Notes for Table 3.2.2-5:

Standard Notes:

A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

E Consistent with NUREG-1801 for material, environment, and aging effect, but a different aging management program is credited or NUREG-1801 identifies a plant-specific aging management program.

Plant Specific Notes:

None 1 The bottom of this tank rests on a concrete foundation. Therefore, the Aboveground Metallic Tanks program (B2.1.15) is credited.

ULNRC-06057 December 20, 2013 Page 15 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to revise aging evaluation lines for insulation based on LR-ISG-2012-02 Table 3.2.2-6 (Page 3.2-72) is revised as follows (deleted text shown in strikethrough and new text shown underlined):

Table 3.2.2-6 Engineered Safety Features - Summary of Aging Management Evaluation - Residual Heat Removal System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Heat PB Carbon Steel Closed Cycle Cumulative Time-Limited Aging None None H, 12 Exchanger Cooling Water fatigue Analysis evaluated for (Residual Heat (Int) damage the period of extended Removal) operation Heat PB Stainless Treated Cumulative Time-Limited Aging None None H, 12 Exchanger Steel Borated Water fatigue Analysis evaluated for (Residual Heat (Int) damage the period of extended Removal) operation Insulation INS Insulation Plant Indoor Air None None None None J, 2 Calcium (Ext) Reduced External Surfaces VIII.I.S-403 3.4.1.064 A Silicate thermal Monitoring of Mechanical insulation Components (B2.1.21) resistance

ULNRC-06057 December 20, 2013 Page 16 of 136 Notes for Table 3.2.2-6:

Standard Notes:

A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

H Aging effect not in NUREG-1801 for this component, material and environment combination.

J Neither the component nor the material and environment combination is evaluated in NUREG-1801.

Plant Specific Notes:

1 Based on plant operating experience, there are no aging effects requiring management for calcium silicate insulation in a metal jacket in a plant indoor air environment. The insulation does not experience aging effects unless exposed to temperatures, radiation, or chemicals capable of attacking the specific chemical composition of the insulation. The insulation is contained in metal jacket with a vapor barrier to prevent moisture intrusion and is in a non-aggressive air environment that does not experience significant aging effects.

12 These TLAAs are applicable to the Class 2 Heat Exchangers. Section 4.3.8 describes the evaluation of these TLAAs.

ULNRC-06057 December 20, 2013 Page 17 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to Section 3.3.2.1, Materials, Environments, Aging Effects Requiring Management and Aging Management Programs (AMPs), as a result of aging management of components with internal coatings and LR-ISG-2012-02 changes.

Section 3.3.2.1 in Chapter VII of NUREG-1801 for Auxiliary Systems, (Page 3.3-4 thru 3.3-

35) is revised to add the materials, environments, aging effects requiring management and (AMPs) to the sections indicated.

3.3.2.1 Materials, Environments, Aging Effects Requiring Management and Aging Management Programs (AMPs)

Concrete Environment Loss of Material and Cracking 3.3.2.1.2 Fuel Pool Cooling and 3.3.2.1.4 Essential Service Water Cleanup System System 3.3.2.1.10 Chemical and Volume Control Carbon Steel (with Coating or Lining)

System 3.3.2.1.4 Essential Service Water 3.3.2.1.11 Control Building HVAC System System 3.3.2.1.5 Service Water System 3.3.2.1.13 Auxiliary Building HVAC System 3.3.2.1.7 Component Cooling Water 3.3.2.1.14 Fuel Building HVAC System System 3.3.2.1.11 Control Building HVAC 3.3.2.1.15 Miscellaneous Buildings System HVAC System 3.3.2.1.20 Fire Protection System 3.3.2.1.19 Containment Cooling System Condensation 3.3.2.1.20 Fire Protection System 3.3.2.1.14 Fuel Building HVAC System 3.3.2.1.28 Miscellaneous Systems in Scope ONLY for Criterion 10 CFR 54.4(a)(2) 3.3.2.1.19 Containment Cooling Reduced Thermal Insulation Resistance System 3.3.2.1.22 Standby Diesel Generator Loss of Material and Flow Blockage Engine System 3.3.2.1.20 Fire Protection System 3.3.2.1.10 Chemical and Volume Control System

ULNRC-06057 December 20, 2013 Page 18 of 136 Callaway Plant License Renewal Application Amendment 28 Add a new section for the further evaluation for loss of material due to recurring internal corrosion.

Further Evaluation 3.3.2.2.8 (Page 3.3-36) is added as follows (new text shown underlined):

3.3.2.2.8 Loss of Material Due to Recurring Internal Corrosion Actions have been taken to address examples of recurring corrosion due to MIC in the Open-Cycle Cooling Water System program (B2.1.10). Low Frequency Electromagnetic Technique (LFET) is used for screening large areas of piping to detect changes in the wall thickness of the pipe. Thinned areas found during the LFET scan are followed up with pipe wall thickness examinations. In addition to the pipe wall thickness examination, opportunistic visual inspections of the ESW system are also performed whenever the ESW system is opened for maintenance.

Prior to the period of extended operation, an inspection technique will be selected from available technologies to identify internal pipe wall degradation due to MIC for performance of a one-time inspection of a buried carbon steel piping segment that is representative of other accessible carbon steel ESW piping segments.

ULNRC-06057 December 20, 2013 Page 19 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to discussion column as a result of aging management of components with internal coatings and LR-ISG-2012-02 changes for recurring internal corrosion, corrosion under insulation, and Fire Water System AMP, and Aboveground Metallic Tanks AMP.

Table 3.3-1, Summary of Aging Management Programs in Chapter VII of NUREG-1801 for Auxiliary Systems, (Pages 3.3-51, 3.3-58 through 3.3-60, 3.3-66, and 3.3-81) is revised as follows (new text underlined and deleted text shown in strikethrough):

Table 3.3-1 Summary of Aging Management Programs in Chapter VII of NUREG-1801 for Auxiliary Systems Item Component Type Aging Effect / Mechanism Aging Management Further Evaluation Discussion Number Program Recommended 3.3.1.037 Steel (with coating Loss of material due to Open-Cycle Cooling No Consistent with NUREG-1801 for or lining) Piping, general, pitting, crevice, and Water System (B2.1.10) material, environment, and aging piping components, microbiologically-influenced effect, but a different aging and piping elements corrosion; fouling that leads management program exposed to Raw to corrosion; lining/coating Inspection of Internal Surfaces in water degradation Miscellaneous Piping and Ducting Components (B2.1.23) or Fire Water System (B2.1.14) is credited for those components not managed by the Open-Cycle Cooling Water System (B2.1.10) program.

ULNRC-06057 December 20, 2013 Page 20 of 136 Table 3.3-1 Summary of Aging Management Programs in Chapter VII of NUREG-1801 for Auxiliary Systems Item Component Type Aging Effect / Mechanism Aging Management Further Evaluation Discussion Number Program Recommended 3.3.1.064 Steel, Copper alloy Loss of material due to Fire Water System No Consistent with NUREG-1801 Piping, piping general, pitting, crevice, and (B2.1.14) with aging management program components, and microbiologically-influenced exceptions. **The aging piping elements corrosion, fouling that leads management program(s) with exposed to Raw to corrosion; flow blockage exceptions to NUREG-1801 water due to fouling include: Fire Water System (B2.1.14) 3.3.1.065 Aluminum Piping, Loss of material due to pitting Fire Water System No Not applicable. Callaway has no piping components, and crevice corrosion, fouling (B2.1.14) in-scope aluminum piping, piping and piping elements that leads to corrosion; flow components or piping elements exposed to Raw blockage due to fouling exposed to raw water in the fire water protection system auxiliary systems, so the applicable NUREG-1801 line was not used.

3.3.1.066 Stainless steel Loss of material due to pitting Fire Water System No Consistent with NUREG-1801 Piping, piping and crevice corrosion; fouling (B2.1.14) with aging management program components, and that leads to corrosion; flow exceptions. The aging piping elements blockage due to fouling management program(s) with exposed to Raw exceptions to NUREG-1801 water include: Fire Water System (B2.1.14)

ULNRC-06057 December 20, 2013 Page 21 of 136 Table 3.3-1 Summary of Aging Management Programs in Chapter VII of NUREG-1801 for Auxiliary Systems Item Component Type Aging Effect / Mechanism Aging Management Further Evaluation Discussion Number Program Recommended 3.3.1.067 Steel Tanks Loss of material due to Aboveground Metallic No Not applicable. Other than the exposed to Air - general, pitting, and crevice Tanks (B2.1.15) fire water storage tanks that are outdoor (External) corrosion managed by the fire water system program (B2.1.14),

Callaway has no in-scope steel tanks greater than 100,000 gallons exposed to an outdoor air environment within the auxiliary systems, so the applicable NUREG-1801 line was not used.

Consistent with NUREG-1801 with aging management program exceptions. The aging management program(s) with exceptions to NUREG-1801 include: Aboveground Metallic Tanks (B2.1.15).

ULNRC-06057 December 20, 2013 Page 22 of 136 Table 3.3-1 Summary of Aging Management Programs in Chapter VII of NUREG-1801 for Auxiliary Systems Item Component Type Aging Effect / Mechanism Aging Management Further Evaluation Discussion Number Program Recommended 3.3.1.072 Gray cast iron, Loss of material due to Selective Leaching No Consistent with NUREG-1801 Copper alloy (>15% selective leaching (B2.1.19) with aging management program Zn or >8% Al) exceptions. The aging Piping, piping management program(s) with components, and exceptions to NUREG-1801 piping elements, include: Selective Leaching Heat exchanger (B2.1.19) components exposed to Treated water, Closed-cycle cooling water, Soil, Raw water, Waste water 3.3.1.089 Steel, Copper alloy Loss of material due to For fire water system No Consistent with NUREG-1801 Piping, piping general, pitting, and crevice components: Chapter with aging management program components, and corrosion XI.M27 Fire Water exceptions. The aging piping elements System (B2.1.14) or management program(s) with exposed to Moist air other components: exceptions to NUREG-1801 or condensation Inspection of Internal include: Fire Water System and (Internal) Surfaces in Inspection of Internal Surfaces in Miscellaneous Piping Miscellaneous Piping and and Ducting Components Ducting Components (B2.1.23)

(B2.1.23) (B2.1.14)

ULNRC-06057 December 20, 2013 Page 23 of 136 Table 3.3-1 Summary of Aging Management Programs in Chapter VII of NUREG-1801 for Auxiliary Systems Item Component Type Aging Effect / Mechanism Aging Management Further Evaluation Discussion Number Program Recommended 3.3.1.127 Metallic piping, Loss of material due to A plant-specific aging Yes, plant-specific Consistent with NUREG-piping components, recurring internal corrosion management program is (See Subsection 1801.The plant-specific aging and tanks exposed to be evaluated to 3.3.2.2.8) management program(s) used to to raw water or address recurring manage the aging include: Open-waste water internal corrosion Cycle Cooling Water System (B2.1.10)**See further evaluation in Section 3.3.2.2.8.

3.3.1.128 Steel, stainless Loss of material due to Aboveground Metallic No Not applicable. Other than the steel, or aluminum general (steel only), pitting, or Tanks (B2.1.15) fire water storage tanks that are tanks (within the crevice corrosion; cracking managed by the fire water scope of Chapter due to stress corrosion system program (B2.1.14),

XI.M29, cracking (stainless steel and Callaway has no in-scope steel, Aboveground aluminum only) stainless steel, or aluminum Metallic Tanks) tanks greater than 100,000 exposed to soil or gallons exposed to a soil or concrete, or the concrete, or external following external environments within the auxiliary environments air- systems, so the applicable outdoor, air-indoor NUREG-1801 line was not used.

uncontrolled, moist air, condensation

ULNRC-06057 December 20, 2013 Page 24 of 136 Table 3.3-1 Summary of Aging Management Programs in Chapter VII of NUREG-1801 for Auxiliary Systems Item Component Type Aging Effect / Mechanism Aging Management Further Evaluation Discussion Number Program Recommended 3.3.1.129 Steel tanks exposed Loss of material due to Aboveground Metallic No Not applicable. Other than the to soil or concrete; general, pitting, and crevice, Tanks (B2.1.15) fire water storage tanks that are air-indoor corrosion. managed by the fire water uncontrolled, raw system program (B2.1.14),

water, treated water, Callaway has no in-scope steel waste water, tanks greater than 100,000 condensation gallons exposed to a soil or concrete; air-indoor uncontrolled, raw water, treated water, waste water, condensation environments within the auxiliary systems, so the applicable NUREG-1801 line was not used.

3.3.1.130 Metallic sprinklers Loss of material due to Fire Water System No Consistent with NUREG-1801 exposed to air- general (where applicable), (B2.1.14) with aging management program indoor controlled, pitting, crevice, and exceptions. **The aging air-indoor microbiologically-influenced management program(s) with uncontrolled, air- corrosion, fouling that leads exceptions to NUREG-1801 outdoor, moist air, to corrosion; flow blockage include: Fire Water System condensation, raw due to fouling (B2.1.14) water, treated water

ULNRC-06057 December 20, 2013 Page 25 of 136 Table 3.3-1 Summary of Aging Management Programs in Chapter VII of NUREG-1801 for Auxiliary Systems Item Component Type Aging Effect / Mechanism Aging Management Further Evaluation Discussion Number Program Recommended 3.3.1.131 Steel, stainless Loss of material due to Fire Water System No Consistent with NUREG-1801 steel, copper alloy, general (steel, and copper (B2.1.14) with aging management program or aluminum fire alloy only), pitting, crevice, exceptions. The aging water system piping, and microbiologically- management program(s) with piping components influenced corrosion, fouling exceptions to NUREG-1801 and piping elements that leads to corrosion; flow include: Fire Water System exposed to air- blockage due to fouling (B2.1.14) indoor uncontrolled (internal), air-outdoor (internal), or condensation (internal) 3.3.1.132 Insulated steel, Loss of material due to External Surfaces No Consistent with NUREG-1801.

stainless steel, general (steel, and copper Monitoring of Mechanical copper alloy, alloy only), pitting, and Components (B2.1.21) or aluminum, or copper crevice corrosion; cracking Aboveground Metallic alloy (> 15% Zn) due to stress corrosion Tanks (B2.1.15) (for piping, piping cracking (aluminum, stainless tanks only) components, and steel and copper alloy (>15%

tanks exposed to Zn) only) condensation, air-outdoor

ULNRC-06057 December 20, 2013 Page 26 of 136 Table 3.3-1 Summary of Aging Management Programs in Chapter VII of NUREG-1801 for Auxiliary Systems Item Component Type Aging Effect / Mechanism Aging Management Further Evaluation Discussion Number Program Recommended 3.3.1.133 Underground HDPE Cracking, blistering, change Buried and Underground No Consistent with NUREG-1801.

piping, piping in color due to water Piping and Tanks components, and absorption (B2.1.25) piping elements in an air-indoor uncontrolled or condensation (external) environmen 3.3.1.134 Steel, stainless Loss of material due to Inspection of Internal No Consistent with NUREG-1801 for steel, or copper alloy general (steel and copper Surfaces in material, environment, and aging piping, piping alloy only), pitting, crevice, Miscellaneous Piping effect, but a different aging components, and and microbiologically and Ducting Components management program External piping elements, and influenced corrosion, fouling (B2.1.23) Surfaces Monitoring of heat exchanger that leads to corrosion Mechanical Components components (B2.1.23) is credited for the exposed to a raw submerged service water pumps water environment because the material and (for nonsafety- environment combinations are related components the same for the internal and not covered by NRC external surfaces.

GL 89-13) 3.3.1.135 Steel or stainless Loss of material due to External Surfaces No Consistent with NUREG-1801.

steel pump casings general (steel only), pitting, Monitoring of Mechanical submerged in a crevice, and microbiologically Components (B2.1.21) waste water (internal influenced corrosion and external) environment

ULNRC-06057 December 20, 2013 Page 27 of 136 Table 3.3-1 Summary of Aging Management Programs in Chapter VII of NUREG-1801 for Auxiliary Systems Item Component Type Aging Effect / Mechanism Aging Management Further Evaluation Discussion Number Program Recommended 3.3.1.136 Steel, stainless steel Loss of material due to Fire Water System No Consistent with NUREG-1801 or aluminum fire general (steel only), pitting, (B2.1.14) with aging management program water storage tanks crevice, and exceptions. **The aging exposed to air- microbiologically-influenced management program(s) with indoor uncontrolled, corrosion, fouling that leads exceptions to NUREG-1801 air-outdoor, to corrosion; cracking due to include: Fire Water System condensation, moist stress corrosion cracking (B2.1.14) air, raw water, (stainless steel and aluminum treated water only) 3.3.1.137 Steel, stainless steel Loss of material due to Aboveground Metallic No Not applicable. Other than the or aluminum tanks general (steel only) pitting Tanks (B2.1.15) fire water storage tanks that are (within the scope of and crevice corrosion managed by the fire water Chapter XI.M29, system program (B2.1.14),

Aboveground Callaway has no in-scope steel, Metallic Tanks) stainless steel, or aluminum exposed to treated tanks greater than 100,000 water, treated gallons exposed to treated water borated water or treated borated water within the auxiliary systems, so the applicable NUREG-1801 line was not used.

ULNRC-06057 December 20, 2013 Page 28 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to add submerged piping and piping embedded in concrete Table 3.3.2-2 (Pages 3.3-88, and 3.3-89) is revised as follows (new text shown underlined):

Table 3.3.2-2 Auxiliary Systems - Summary of Aging Management Evaluation - Spent Fuel Pool Cooling and Cleanup System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping PB Stainless Concrete None None VII.J.AP-19 3.3.1.120 A steel Piping PB Stainless Treated Cracking Water Chemistry (B2.1.2) VII.A3.A-56 3.3.1.124 A steel Borated Water and One-Time Inspection (External) (B2.1.18)

Piping PB Stainless Treated Loss of Water Chemistry (B2.1.2) VII.A3.AP-79 3.3.1.125 A steel Borated Water material and One-Time Inspection (External) (B2.1.18)

ULNRC-06057 December 20, 2013 Page 29 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to add LR-ISG-2012-02 aging evaluation lines for identification of components with internal coatings, recurring internal corrosion, corrosion under insulation, and underground HDPE piping.

Table 3.3.2-4 (Pages 3.3-94, 3.3-97 through 3.3-98) is revised as follows (new text underlined and deleted text shown in strikethrough):

Table 3.3.2-4 Auxiliary Systems - Summary of Aging Management Evaluation - Essential Service Water System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping LBS, PB, Carbon Steel Raw Water (Int) Loss of material Open-Cycle Cooling VII.C1.A-400 3.3.1.127 E, 5 SIA Water System (B2.1.10)

Piping PB Carbon Steel Condensation Loss of material External Surfaces VII.C1.A-405 3.3.1.132 A (Ext) and cracking Monitoring of Mechanical Components (B2.1.21)

Piping LBS, PB, Carbon Steel Raw Water (Int) Wall thinning Open-Cycle Cooling VII.C1.A-409 3.3.1.126 E, 4 SIA Water System (B2.1.10) E, 3 Piping PB HDPE Buried (Ext) Cracking Time-Limited Aging None None H, 4 Analysis evaluated for H, 3 the period of extended operation Piping PB HDPE Underground (Ext) Cracking, Buried and Underground None None G, 2 blistering, change Piping and Tanks VII.I.A-406 3.3.1.133 A in color (B2.1.25)

ULNRC-06057 December 20, 2013 Page 30 of 136 Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping PB HDPE Plant Indoor Air None None None None G, 3 (Ext) G, 2 Strainer FIL, PB Carbon Steel Plant Indoor Air Loss of material External Surfaces VII.I.A-77 3.3.1.078 A (with coating (Ext) Monitoring of or lining) Mechanical Components (B2.1.21)

Strainer FIL, PB Carbon Steel Raw Water (Int) Loss of material Open-Cycle Cooling VII.C1.AP-194 3.3.1.037 A (with coating Water System (B2.1.10) or lining)

Notes for Table 3.3.2-4:

Standard Notes:

A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

D Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

E Consistent with NUREG-1801 for material, environment, and aging effect, but a different aging management program is credited or NUREG-1801 identifies a plant-specific aging management program.

F Material not in NUREG-1801 for this component.

G Environment not in NUREG-1801 for this component and material.

H Aging effect not in NUREG-1801 for this component, material, and environment combination.

Plant Specific Notes:

ULNRC-06057 December 20, 2013 Page 31 of 136 1 External Surfaces Monitoring of Mechanical Components program (B2.1.21) is used instead of Open Cycle Cooling Water program (B2.1.10) to manage the aging of the external surfaces of nonsafety-related components exposed to raw water.

2 HDPE piping is in an underground vault and potentially exposed to groundwater.

32 HDPE components in a plant indoor air environment are not exposed to an aggressive chemical environment that would concentrate contaminants and degrade HDPE chemical and mechanical properties. HDPE is not exposed to ozone, ionizing radiation or a UV source (sunlight or fluorescent light) that would result in aging. Operating temperatures do not exceed 140°F.

HDPE components in a plant indoor air environment have no aging effects requiring aging management.

43 This TLAA is applicable to the high-density polyethylene (HDPE) piping. Section 4.7.7 describes the evaluation of this TLAA for the replacement ESW piping.

54 Open-Cycle Cooling Water System program (B2.1.10) is used instead of Flow-Accelerated Corrosion program (B2.1.7) to manage wall thinning due to erosion of carbon steel piping exposed to rawwater.

5 The Open-Cycle Cooling Water System program (B2.1.10) is used to monitor for recurring internal corrosion in the ESW system.

See Further Evaluation 3.3.2.2.8.

ULNRC-06057 December 20, 2013 Page 32 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to add LR-ISG-2012-02 aging evaluation lines for identification of components with internal coatings and evaluation of nonsafety-related components, not covered by NRC GL 89-13.

Table 3.3.2-5 (Pages 3.3-100 through 3.3-104) is revised as follows (new text underlined and deleted text shown in strikethrough):

Table 3.3.2-5 Auxiliary Systems - Summary of Aging Management Evaluation - Service Water System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping LBS, PB, Carbon Steel Raw Water (Int) Loss of material Inspection of Internal VII.C1.A-194 3.3.1.037 E, 1 SIA Surfaces in VII.C1.A-408a 3.3.1.134 B Miscellaneous Piping and Ducting Components (B2.1.23)

Piping LBS, PB, Stainless Raw Water (Int) Loss of material Inspection of Internal VII.C1.A-54 3.3.1.040 E, 1 SIA Steel Surfaces in VII.C1.A-409a 3.3.1.134 B Miscellaneous Piping and Ducting Components (B2.1.23)

Pump PB Cast Iron Raw Water (Ext) Loss of material External Surfaces VII.C1.A-194 3.3.1.037 E, 3 (Gray Cast Monitoring of VII.C1.A-408a 3.3.1.134 Iron) Mechanical Components (B2.1.21)

ULNRC-06057 December 20, 2013 Page 33 of 136 Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Pump PB Cast Iron Raw Water (Int) Loss of material External Surfaces VII.C1.A-194 3.3.1.037 E, 3 (Gray Cast Monitoring of VII.C1.A-408a 3.3.1.134 Iron) Mechanical Components (B2.1.21)

Strainer PB Carbon Steel Plant Indoor Air Loss of material External Surfaces VII.I.A-77 3.3.1.078 A (with coating (Ext) Monitoring of or lining) Mechanical Components (B2.1.21)

Strainer PB Carbon Steel Raw Water (Int) Loss of material Inspection of Internal VII.C1.AP-194 3.3.1.037 E, 1 (with coating Surfaces in or lining) Miscellaneous Piping and Ducting Components (B2.1.23)

Thermowell PB Stainless Raw Water (Int) Loss of material Inspection of Internal VII.C1.A-54 3.3.1.040 E, 1 Steel Surfaces in VII.C1.A-409a 3.3.1.134 B Miscellaneous Piping and Ducting Components (B2.1.23)

Tubing PB Carbon Steel Raw Water (Int) Loss of material Inspection of Internal VII.C1.A-194 3.3.1.037 E, 1 Surfaces in VII.C1.A-408a 3.3.1.134 B Miscellaneous Piping and Ducting Components (B2.1.23)

Tubing PB Stainless Raw Water (Int) Loss of material Inspection of Internal VII.C1.A-54 3.3.1.040 E, 1 Steel Surfaces in VII.C1.A-409a 3.3.1.134 B Miscellaneous Piping and Ducting Components (B2.1.23)

ULNRC-06057 December 20, 2013 Page 34 of 136 Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Valve LBS, PB, Carbon Steel Raw Water (Int) Loss of material Inspection of Internal VII.C1.A-194 3.3.1.037 E, 1 SIA Surfaces in VII.C1.A-408a 3.3.1.134 B Miscellaneous Piping and Ducting Components (B2.1.23)

Valve PB Cast Iron Raw Water (Int) Loss of material Inspection of Internal VII.C1.A-194 3.3.1.037 E, 1 (Gray Cast Surfaces in VII.C1.A-408a 3.3.1.134 B Iron) Miscellaneous Piping and Ducting Components (B2.1.23)

Valve PB Copper Alloy Raw Water (Int) Loss of material Inspection of Internal VII.C1.A-194 3.3.1.037 E, 1 Surfaces in VII.C1.A-408a 3.3.1.134 B Miscellaneous Piping and Ducting Components (B2.1.23)

Valve PB Ductile Iron Raw Water (Int) Loss of material Inspection of Internal VII.C1.A-194 3.3.1.037 E, 1 Surfaces in VII.C1.A-408a 3.3.1.134 B Miscellaneous Piping and Ducting Components (B2.1.23)

Valve LBS, PB, Stainless Raw Water (Int) Loss of material Inspection of Internal VII.C1.A-54 3.3.1.040 E, 1 SIA Steel Surfaces in VII.C1.A-409a 3.3.1.134 B Miscellaneous Piping and Ducting Components (B2.1.23)

ULNRC-06057 December 20, 2013 Page 35 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to add LR-ISG-2012-02 aging evaluation lines for identification of components with internal coatings and revise AMR references.

Table 3.3.2-7 (Pages 3.3-108 through 3.3-112) is revised as follows (new text underlined and deleted text shown in strikethrough):

Table 3.3.2-7 Auxiliary Systems - Summary of Aging Management Evaluation - Component Cooling Water System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Heat PB Carbon Steel Closed Cycle Loss of material Closed Treated Water VII.C2.AP-202 3.3.1.045 A Exchanger (with coating Cooling Water Systems (B2.1.11)

(CCW Heat or lining) (Ext)

Exchanger)

Heat PB Carbon Steel Raw Water (Int) Loss of material Open-Cycle Cooling VII.C1-AP-183 3.3.1.038 A Exchanger (with coating Water System (B2.1.10) VII.C1.AP-194 3.3.1.037 (CCW Heat or lining)

Exchanger)

Piping LBS, PB, Carbon Steel Condensation (Int) Loss of material Inspection of Internal VIII.G.A-23 3.3.1.089 B SIA Surfaces in VIII.B1.SP-60 3.4.1.037 Miscellaneous Piping and Ducting Components (B2.1.23)

Tank LBS, PB, Carbon Steel Condensation (Int) Loss of material Inspection of Internal VIII.G.A-23 3.3.1.089 D SIA Surfaces in VIII.B1.SP-60 3.4.1.037 B Miscellaneous Piping and Ducting Components (B2.1.23)

ULNRC-06057 December 20, 2013 Page 36 of 136 Notes for Table 3.3.2-7:

Standard Notes:

A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP D Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

Plant Specific Notes:

None

ULNRC-06057 December 20, 2013 Page 37 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to add LR-ISG-2012-02 aging evaluation lines for identification of corrosion under insulation, revised the aging evaluation for calcium silicate insulation, and revised the aging evaluation of non-safety related components not covered by NRC GL 89-13.

Table 3.3.2-10 (Pages 3.3-131, 3.3-137 through 3.3-139, 3.3-146, 3.3-147) is revised as follows (new text underlined and deleted text shown in strikethrough):

Table 3.3.2-10 Auxiliary Systems - Summary of Aging Management Evaluation - Chemical and Volume Control System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Heat PB Carbon Steel Closed Cycle Cumulative Time-Limited Aging None None H, 4 Exchanger Cooling Water (Int) fatigue damage Analysis evaluated for H, 2 (CVCS Excess the period of extended Letdown) operation Heat PB Carbon Steel Closed Cycle Cumulative Time-Limited Aging None None H, 4 Exchanger Cooling Water (Int) fatigue damage Analysis evaluated for H, 2 (CVCS the period of extended Letdown) operation Heat PB Stainless Treated Borated Cracking Water Chemistry VII.E1.A-69 3.3.1.003 E-2 Exchanger Steel Water (Int) (B2.1.2) and One-Time E, 1 (CVCS Inspection (B2.1.18)

Letdown)

Insulation INS Insulation Plant Indoor Air None None None None J, 1 Calcium (Ext) Reduced thermal External Surfaces VIII.I.S-403 3.4.1.064 A Silicate insulation Monitoring of resistance Mechanical Components

ULNRC-06057 December 20, 2013 Page 38 of 136 (B2.1.21)

Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping LBS Carbon Steel Condensation Loss of material External Surfaces VII.E1.A-405 3.3.1.132 A (Ext) and cracking Monitoring of Mechanical Components (B2.1.21)

Piping LBS, SIA Stainless Condensation Loss of material External Surfaces VII.E1.A-405 3.3.1.132 A Steel (Ext) and cracking Monitoring of Mechanical Components (B2.1.21)

Piping LBS, SIA Stainless Raw Water (Int) Loss of material Inspection of Internal VII.C1.A-54 3.3.1.040 E-1 Steel Surfaces in VII.C1.A-409a 3.3.1.134 B Miscellaneous Piping and Ducting Components (B2.1.23)

Piping LBS, SIA Stainless Raw Water (Int) Loss of material Inspection of Internal VII.C1.A-409a 3.3.1.134 B Steel Surfaces in Miscellaneous Piping and Ducting Components (B2.1.23)

Valve LBS, SIA Stainless Raw Water (Int) Loss of material Inspection of Internal VII.C1.A-54 3.3.1.040 E-1 Steel Surfaces in VII.C1.A-409a 3.3.1.134 B Miscellaneous Piping and Ducting Components (B2.1.23)

Notes for Table 3.3.2-10:

Standard Notes:

ULNRC-06057 December 20, 2013 Page 39 of 136 A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

D Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

E Consistent with NUREG-1801 for material, environment, and aging effect, but a different aging management program is credited or NUREG-1801 identifies a plant-specific aging management program.

H Aging effect not in NUREG-1801 for this component, material and environment combination.

J Neither the component nor the material and environment combination is evaluated in NUREG-1801.

Plant Specific Notes:

1 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program (B2.1.23) is used instead of the Open Cycle Cooling Water program (B2.1.10) to manage the aging of the internal surfaces of stainless steel components exposed to raw water.

21 The One-Time Inspection program (B2.1.18) is used to verify the effectiveness of the Water Chemistry program (B2.1.2) to manage these aging effects.

3. Based on plant operating experience, there are no aging effects requiring management for calcium silicate insulation in a metal jacket in a plant indoor air environment. The insulation does not experience aging effects unless exposed to temperatures, radiation, or chemicals capable of attacking the specific chemical composition of the insulation. The insulation is contained in metal jacket with a vapor barrier to prevent moisture intrusion and is in a non-aggressive air environment that does not experience significant aging effects.

42 These TLAAs are applicable to the Class 2 Heat Exchangers. Section 4.3.8 describes the evaluation of these TLAAs.

ULNRC-06057 December 20, 2013 Page 40 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to add LR-ISG-2012-02 aging evaluation lines for insulated piping, revise the standard note non-safety related components in a raw water environment, and identification of components with internal coatings Table 3.3.2-11 (Pages 3.3-149, 3.3-153 through 3.3-158, and 3.3-160) is revised as follows (new text underlined and deleted text shown in strikethrough):

Table 3.3.2-11 Auxiliary Systems - Summary of Aging Management Evaluation - Control Building HVAC Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Damper FB Carbon Steel Ventilation Loss of material Fire Protection (B2.1.13) VII.F1.A-08 3.3.1.090 E, 4 (Galvanized) Atmosphere (Int) E, 3 Damper PB Carbon Steel Ventilation Loss of material Fire Protection (B2.1.13) VII.F1.A-08 3.3.1.090 E, 4 (Galvanized) Atmosphere (Int) E, 3 Heat HT Aluminum Ventilation Reduction of heat Open-Cycle Cooling None None H, 5 Exchanger Atmosphere (Ext) transfer Water System (B2.1.10) H, 4 (Control Building HVAC)

Heat HT Aluminum Ventilation Loss of material Open-Cycle Cooling VII.F1.AP-142 3.3.1.092 E, 6 Exchanger Atmosphere (Ext) Water System (B2.1.10) E, 5 (Control Building HVAC)

Heat PB Carbon Steel Dry Gas (Ext) None None VII.J.AP-6 3.3.1.121 A Exchanger (with coating (Control or lining)

Building HVAC)

ULNRC-06057 December 20, 2013 Page 41 of 136 Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Heat PB Carbon Steel Raw Water (Int) Loss of material Open-Cycle Cooling VII.C1.AP-194 3.3.1.037 A Exchanger (with coating Water System (B2.1.10)

(Control or lining)

Building HVAC)

Heat HT, PB Copper Alloy Ventilation Reduction of heat Open-Cycle Cooling None None H, 5 Exchanger Atmosphere (Ext) transfer Water System (B2.1.10) H, 4 (Control Building HVAC)

Heat PB Copper Alloy Ventilation Loss of material Open-Cycle Cooling VII.F1.AP-109 3.3.1.079 E, 6 Exchanger Atmosphere (Ext) Water System (B2.1.10) E, 5 (Control Building HVAC)

Heat HT Copper Alloy Ventilation Loss of material Open-Cycle Cooling VII.F1.AP-109 3.3.1.079 E, 6 Exchanger Atmosphere (Ext) Water System (B2.1.10) E, 5 (Control Building HVAC)

Piping LBS Carbon Steel Condensation Loss of material External Surfaces VII.F1.A-405 3.3.1.132 A (Ext) and cracking Monitoring of Mechanical Components (B2.1.21)

Piping LBS Carbon Steel Raw Water (Int) Loss of material Inspection of Internal VII.C1.AP-194 3.3.1.037 E, 2 Surfaces in VII.C1.A-408a 3.3.1.134 B Miscellaneous Piping and Ducting Components (B2.1.23)

Piping PB Copper Alloy Plant Indoor Air Loss of material External Surfaces VII.F1.AP-109 3.3.1.079 A, 3 (Ext) Monitoring of A, 2 Mechanical Components (B2.1.21)

ULNRC-06057 December 20, 2013 Page 42 of 136 Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping PB Stainless Condensation Loss of material External Surfaces VII.F1.A-405 3.3.1.132 A Steel (Ext) and cracking Monitoring of Mechanical Components (B2.1.21)

Piping LBS, SIA Stainless Raw Water (Int) Loss of material Inspection of Internal VII.C1.A-54 3.3.1.040 B Steel Surfaces in VII.C1.A-409a 3.3.1.134 Miscellaneous Piping and Ducting Components (B2.1.23)

Solenoid Valve PB Copper Alloy Plant Indoor Air Loss of material External Surfaces VII.F1.AP-109 3.3.1.079 A, 3 (Ext) Monitoring of A, 2 Mechanical Components (B2.1.21)

Tubing LBS, PB Stainless Raw Water (Int) Loss of material Inspection of Internal VII.C1.A-54 3.3.1.040 E, 2 Steel Surfaces in VII.C1.A-409a 3.3.1.134 B Miscellaneous Piping and Ducting Components (B2.1.23)

Valve PB, SIA Copper Alloy Plant Indoor Air Loss of material External Surfaces VII.F1.AP-109 3.3.1.079 A, 3 (Ext) Monitoring of A, 2 Mechanical Components (B2.1.21)

Notes for Table 3.3.2-11:

Standard Notes:

A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

ULNRC-06057 December 20, 2013 Page 43 of 136 Notes for Table 3.3.2-11: (continued)

C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

D Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

E Consistent with NUREG-1801 for material, environment, and aging effect, but a different aging management program is credited or NUREG-1801 identifies a plant-specific aging management program.

H Aging effect not in NUREG-1801 for this component, material and environment combination.

Plant Specific Notes:

1 The subject component is enclosed within another component. Loss of material on the external surface of the subject component is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program (B2.1.23).

2 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program (B2.1.23) is used instead of the Open-Cycle Cooling Water program since these components are nonsafety-related drains.

32 Component is refrigeration piping which is expected to experience condensation during times of elevated humidity on the external surface.

43 Fire Protection (B2.1.13) manages the aging effects associated with this fire damper material and environment combination.

54 Reduction of heat transfer of the air-side of safety-related air-to-water heat exchangers is managed by the Open-Cycle Cooling Water System program (B2.1.10) consistent with Callaway commitments to GL 89-13.

65 Loss of material of the air-side of safety-related air-to-water heat exchangers is managed by Open-Cycle Cooling Water System program (B2.1.10) consistent with Callaway commitments to GL 89-13.

ULNRC-06057 December 20, 2013 Page 44 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to add LR-ISG-2012-02 aging evaluation lines for identification of components with the potential for corrosion under insulation.

Table 3.3.2-13 (Pages 3.3-168) is revised as follows (new text underlined):

Table 3.3.2-13 Auxiliary Systems - Summary of Aging Management Evaluation - Auxiliary Building HVAC System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping LBS Carbon Steel Condensation Loss of material External Surfaces VII.F2.A-405 3.3.1.132 A (Ext) and cracking Monitoring of Mechanical Components (B2.1.21)

Table 3.3.2-14 (Pages 3.3-177) is revised as follows (new text underlined):

Table 3.3.2-14 Auxiliary Systems - Summary of Aging Management Evaluation - Fuel Building HVAC System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping LBS Carbon Steel Condensation Loss of material External Surfaces VII.I.A-405 3.3.1.132 A (Ext) and cracking Monitoring of Mechanical Components (B2.1.21)

ULNRC-06057 December 20, 2013 Page 45 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to add LR-ISG-2012-02 aging evaluation lines for identification of components with the potential for corrosion under insulation.

Table 3.3.2-15 (Pages 3.3-186) is revised as follows (new text underlined):

Table 3.3.2-15 Auxiliary Systems - Summary of Aging Management Evaluation - Miscellaneous Buildings HVAC System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping LBS Carbon Steel Condensation Loss of material External Surfaces VII.I.A-405 3.3.1.132 A (Ext) and cracking Monitoring of Mechanical Components (B2.1.21)

Table 3.3.2-19 (Pages 3.3-201) is revised as follows (new text underlined):

Table 3.3.2-19 Auxiliary Systems - Summary of Aging Management Evaluation - Containment Cooling System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping PB Carbon Steel Condensation Loss of material External Surfaces VII.F3.A-405 3.3.1.132 A (Ext) and cracking Monitoring of Mechanical Components (B2.1.21)

ULNRC-06057 December 20, 2013 Page 46 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to add LR-ISG-2012-02 aging evaluation lines for Fire Water System AMP, and Aboveground Metallic Tanks AMP.

Table 3.3.2-20 (Pages 3.3-204, and 3.3-216) is revised as follows (new text underlined and deleted text shown in strikethrough):

Table 3.3.2-20 Auxiliary Systems - Summary of Aging Management Evaluation - Fire Protection System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Filter PB Carbon Steel Condensation (Int) Loss of material External Surfaces VII.G.A-23 3.3.1.089 B and flow blockage Monitoring of VII.G.A-404 3.3.1.131 Mechanical Components (B2.1.21)

Fire Water System (B2.1.14)

Filter PB Carbon Steel Raw Water (Int) Loss of material Fire Water System VII.G.A-33 3.3.1.064 B and flow blockage (B2.1.14)

Flexible Hoses PB Stainless Raw Water (Int) Loss of material Fire Water System VII.G.A-55 3.3.1.066 B Steel and flow blockage (B2.1.14)

Flow Element PB Carbon Steel Raw Water (Int) Loss of material Fire Water System VII.G.A-33 3.3.1.064 B and flow blockage (B2.1.14)

Flow Orifice PB Carbon Steel Raw Water (Int) Loss of material Fire Water System VII.G.A-33 3.3.1.064 B and flow blockage (B2.1.14)

ULNRC-06057 December 20, 2013 Page 47 of 136 Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Flow Orifice PB Stainless Raw Water (Ext) Loss of material Fire Water System VII.G.A-55 3.3.1.066 B Steel and flow blockage (B2.1.14)

Flow Orifice PB Stainless Raw Water (Int) Loss of material Fire Water System VII.G.A-55 3.3.1.066 B Steel and flow blockage (B2.1.14)

Heat PB Carbon Steel Raw Water (Int) Loss of material Fire Water System VII.G.A-33 3.3.1.064 B Exchanger and flow blockage (B2.1.14)

(DFP Jacket Water)

Heat PB Copper Alloy Raw Water (Ext) Loss of material Fire Water System VII.G.AP-197 3.3.1.064 B Exchanger and flow blockage (B2.1.14)

(DFP Jacket Water)

Hose Station PB Copper Alloy Raw Water (Int) Loss of material Fire Water System VII.G.AP-197 3.3.1.064 B and flow blockage (B2.1.14)

Piping PB Carbon Steel Condensation (Int) Loss of material External Surfaces VII.G.A-23 3.3.1.089 B and flow blockage Monitoring of VII.G.A-404 3.3.1.131 D Mechanical Components (B2.1.21)

Fire Water System (B2.1.14)

Piping PB, SIA Carbon Steel Raw Water (Int) Loss of material Fire Water System VII.G.A-33 3.3.1.064 B and flow blockage (B2.1.14) D Piping PB Carbon Steel Condensation (Int) Loss of material Inspection of Internal VII.G.A-23 3.3.1.089 B (Galvanized) and flow blockage Surfaces in VII.G.A-404 3.3.1.131 D Miscellaneous Piping and Ducting Components (B2.1.23)

Fire Water System (B2.1.14)

ULNRC-06057 December 20, 2013 Page 48 of 136 Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping PB Carbon Steel Raw Water (Int) Loss of material Fire Water System VII.G.A-33 3.3.1.064 B (Galvanized) and flow blockage (B2.1.14)

Piping PB Copper Alloy Condensation (Int) Loss of material Inspection of Internal VII.G.AP-143 3.3.1.089 B and flow blockage Surfaces in VII.G.A-404 3.3.1.131 Miscellaneous Piping and Ducting Components (B2.1.23)

Fire Water System (B2.1.14)

Piping PB, SIA Carbon Steel Raw Water (Int) Loss of material Fire Water System VII.G.A-33 3.3.1.064 B and flow blockage (B2.1.14)

Piping PB, SIA Copper Alloy Raw Water (Int) Loss of material Fire Water System VII.G.AP-197 3.3.1.064 B and flow blockage (B2.1.14)

Spray Nozzle SP Copper Alloy Atmosphere/ Loss of material External Surfaces VII.I.AP-159 3.3.1.081 B Weather (Ext) and flow blockage Monitoring of VII.G.A-403 3.3.1.130 Mechanical Components (B2.1.21)

Fire Water System (B2.1.14)

Spray Nozzle SP Copper Alloy Condensation (Int) Loss of material Inspection of Internal VII.G.AP-143 3.3.1.089 B and flow blockage Surfaces in VII.G.A-404 3.3.1.131 Miscellaneous Piping and Ducting Components (B2.1.23)

Fire Water System (B2.1.14)

Spray Nozzle SP Copper Alloy Plant Indoor Air None None VII.J.AP-144 3.3.1.114 A (Ext) Loss of material Fire Water System VII.G.A-403 3.3.1.130 B and flow blockage (B2.1.14)

ULNRC-06057 December 20, 2013 Page 49 of 136 Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Spray Nozzle SP Copper Alloy Raw Water (Int) Loss of material Fire Water System VII.G.AP-197 3.1.064 B and flow blockage (B2.1.14)

Tank PB Carbon Steel Atmosphere/ Loss of material Aboveground Metallic VII.H1.A-95 3.3.1.067 A Weather (Ext) and cracking Tanks (B2.1.15) VII.G.A-412 3.3.1.136 B Fire Water System (B2.1.14)

Tank PB Carbon Steel Condensation (Int) Loss of material Inspection of Internal VII.G.A-23 3.3.1.089 D and flow blockage Surfaces in VII.G.A-404 3.3.1.131 Miscellaneous Piping and Ducting Components (B2.1.23)

Fire Water System (B2.1.14)

Tank PB Carbon Steel Raw Water (Int) Loss of material Fire Water System VII.G.A-33 3.3.1.064 B and flow blockage (B2.1.14) D Tank PB Carbon Steel Raw Water (Int) Loss of material Fire Water System VII.H2.AP-194 3.3.1.037 E, 4 (with coating (B2.1.14) or lining)

Tubing PB Copper Alloy Condensation (Int) Loss of material Inspection of Internal VII.G.AP-143 3.3.1.089 B and flow blockage Surfaces in VII.G.A-404 3.3.1.131 Miscellaneous Piping and Ducting Components (B2.1.23)

Fire Water Tubing PB Copper Alloy Raw Water (Int) Loss of material Fire Water System VII.G.AP-197 3.3.1.064 B and flow blockage (B2.1.14)

ULNRC-06057 December 20, 2013 Page 50 of 136 Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Valve PB Carbon Steel Raw Water (Int) Loss of material Fire Water System VII.G.A-33 3.3.1.064 B and flow blockage (B2.1.14)

Valve PB Copper Alloy Condensation (Int) Loss of material Inspection of Internal VII.G.AP-143 3.3.1.089 B and flow blockage Surfaces in VII.G.A-404 3.3.1.131 Miscellaneous Piping and Ducting Components (B2.1.23)

Fire Water System B2.1.14)

Valve PB, SIA Copper Alloy Raw Water (Int) Loss of material Fire Water System VII.G.AP-197 3.3.1.064 B and flow blockage (B2.1.14)

Notes for Table 3.3.2-20:

Standard Notes:

A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

D Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

E Consistent with NUREG-1801 for material, environment, and aging effect, but a different aging management program is credited or NUREG-1801 identifies a plant-specific aging management program.

G Environment not in NUREG-1801 for this component and material.

Plant Specific Notes:

1 The fire water storage tanks rest on a sand cushion surrounded by a reinforced concrete ring beam.

ULNRC-06057 December 20, 2013 Page 51 of 136 Notes for Table 3.3.2-20: (continued) 2 PVC in a wastewater environment is unaffected by water, concentrated alkalies, nonoxidizing acids, oils, ozone, or humidity changes. PVC in a waste water environment is not exposed to direct sunlight or ionizing radiation. Therefore PVC in a wastewater environment has no aging effect.

3 The external surface of these pumps components will be managed by the External Surfaces Monitoring of Mechanical Components program (B2.1.21).

4 The Fire Water System (B2.1.14) program is used to manage components in the fire water system.

ULNRC-06057 December 20, 2013 Page 52 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to identify that inspections of the fuel oil storage tank coatings are inspected by the Fuel Oil Chemistry program (B2.1.16).

Table 3.3.2-21 (Pages 3.3-219 and 3.3-220) is revised as follows (new text underlined and deleted text shown in strikethrough):

Table 3.3.2-21 Auxiliary Systems - Summary of Aging Management Evaluation - Emergency Diesel Engine Fuel Oil Storage and Transfer System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Tank PB Carbon Steel Fuel Oil (Int) Loss of material Fuel Oil Chemistry VII.H1.AP-105 3.3.1.070 A, 2 (B2.1.16) and One-Time Inspection (B2.1.18)

Notes for Table 3.3.2-21:

Standard Notes:

A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

D Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

G Environment not in NUREG-1801 for this component and material.

ULNRC-06057 December 20, 2013 Page 53 of 136 Notes for Table 3.3.2-21: (continued)

Plant Specific Notes:

1. Loss of preload for underground bolting is managed by the Bolting Integrity program (B2.1.8).

2. The internal surface of this tank is coated, and the aging effect includes flow blockage due to degradation of the coating.

Inspections of the internal surface of the tank performed under the Fuel Oil Chemistry program (B2.1.16) include inspections of the coating.

ULNRC-06057 December 20, 2013 Page 54 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to revise the aging evaluation for calcium silicate insulation based on LR-ISG-2012-02 changes.

Table 3.3.2-22 (Pages 3.3-228) is revised as follows (new text underlined and deleted text shown in strikethrough):

Table 3.3.2-22 Auxiliary Systems - Summary of Aging Management Evaluation - Standby Diesel Generator Engine System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping PB Carbon Steel Diesel Exhaust Cumulative Time-Limited Aging None None H, 2 (Int) fatigue damage Analysis evaluated for H, 1 the period of extended operation Insulation INS Insulation Plant Indoor Air None None None None J, 1 Calcium (Ext) Reduced thermal External Surfaces VIII.I.S-403 3.4.1.064 A Silicate insulation Monitoring of resistance Mechanical Components (B2.1.21)

Notes for Table 3.3.2-22:

Standard Notes:

A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

ULNRC-06057 December 20, 2013 Page 55 of 136 Notes for Table 3.3.2-22: (continued)

C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

D Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

H Aging Effect not in NUREG-1801 for this component, material and environment combination.

J Neither the component nor the material and environment combination is evaluated in NUREG-1801.

Plant Specific Notes:

1 Based on plant operating experience, there are no aging effects requiring management for calcium silicate insulation in a metal jacket in a plant indoor air environment. The insulation does not experience aging effects unless exposed to temperatures, radiation, or chemicals capable of attacking the specific chemical composition of the insulation. The insulation is contained in metal jacket with a vapor barrier to prevent moisture intrusion and is in a non-aggressive air environment that does not experience significant aging effects.

21 This TLAA is applicable to the standby diesel generator engine exhaust piping. Section 4.3.5 describes the evaluation of this TLAA.

ULNRC-06057 December 20, 2013 Page 56 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to revise the aging evaluation for submerged grey iron and stainless steel pumps in a waste water environment based on LR-ISG-2012-02 changes Table 3.3.2-26 (Pages 3.3-259, 3.3-260, and 3.3-262) is revised as follows (new text underlined and deleted text shown in strikethrough):

Table 3.3.2-26 Auxiliary Systems - Summary of Aging Management Evaluation - Oily Waste System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Closure Bolting LBS, PB Carbon Steel Waste Water Loss of preload Bolting Integrity (B2.1.8) None None G, 4 (Ext) G, 2 Closure Bolting LBS Stainless Waste Water Loss of preload Bolting Integrity (B2.1.8) None None G, 4 Steel (Ext) G, 2 Pump LBS, PB Cast Iron Waste Water Loss of material External Surfaces VII.E5.AP-281 3.3.1.091 E, 1 (Gray Cast (Int) Monitoring of Mechanical VII.E5.A-410 3.3.1.135 A Iron) Components (B2.1.21)

Pump LBS, PB Cast Iron Waste Water Loss of material External Surfaces VII.E5.AP-281 3.3.1.091 E, 1 (Gray Cast (Ext) Monitoring of Mechanical VII.E5.A-410 3.3.1.135 A Iron) Components (B2.1.21)

Pump LBS, PB Cast Waste Water Loss of material Selective Leaching None None G, 3 Iron(Gray (Ext) (B2.1.19) VII.E5.A-407a 3.3.1.072 B Cast Iron)

ULNRC-06057 December 20, 2013 Page 57 of 136 Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Pump LBS, PB Cast Waste Water Loss of material External Surfaces VII.E5.AP-281 3.3.1.091 E, 1 Iron(Gray (Int) Monitoring of Mechanical VII.E5.A-410 3.3.1.135 A Cast Iron) Components (B2.1.21)

Pump LBS, PB Cast Waste Water Loss of material Selective Leaching None None G, 3 Iron(Gray (Int) (B2.1.19) VII.E5.A-407a 3.3.1-072 B Cast Iron)

Pump LBS Stainless Waste Water Loss of material External Surfaces VII.E5.AP-278 3.3.1.095 E, 1 Steel (Ext) Monitoring of Mechanical VII.E5.A-411 3.3.1.072 A Components (B2.1.21)

Pump LBS Stainless Waste Water Loss of material External Surfaces VII.E5.AP-278 3.3.1.095 E, 1 Steel (Int) Monitoring of Mechanical VII.E5.A-411 3.3.1.072 A Components (B2.1.21)

Valve LBS, PB Cast Waste Water Loss of material Selective Leaching None None G, 3 Iron(Gray (Int) (B2.1.19) VII.E5.A-407a 3.3.1.072 B Cast Iron)

Notes for Table 3.3.2-26:

Standard Notes:

A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

D Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

E Consistent with NUREG-1801 for material, environment, and aging effect, but a different aging management program is credited or NUREG-1801 identifies a plant-specific aging management program.

ULNRC-06057 December 20, 2013 Page 58 of 136 G Environment not in NUREG-1801 for this component and material.

Plant Specific Notes:

1 The External Surfaces Monitoring of Mechanical Components program (B2.1.21) is credited since the component's external surface is exposed to waste water.

2 Since the internal and external environments for this component are the same, the External Surfaces Monitoring of Mechanical Components program (B2.1.21) is credited to manage the aging of the internal surfaces of this component.

3 Gray Cast Iron SSCs with surfaces exposed to Waste Water are subject to loss of material due to selective leaching.

42 Loss of preload for submerged bolting associated with submerged pumps is managed by the Bolting Integrity program (B2.1.8).

ULNRC-06057 December 20, 2013 Page 59 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to revise the aging evaluation for submerged stainless steel pumps in a waste water environment based on LR-ISG-2012-02 changes Table 3.3.2-27 (Pages 3.3-267) is revised as follows (new text underlined and deleted text shown in strikethrough):

Table 3.3.2-27 Auxiliary Systems - Summary of Aging Management Evaluation - Floor and Equipment Drainage System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Pump LBS, SIA Stainless Waste Water Loss of material External Surfaces VII.E5.AP-278 3.3.1.095 E, 1 Steel (Ext) Monitoring of Mechanical VII.E5.A-411 3.3.1.135 A Components (B2.1.21)

Pump LBS, SIA Stainless Waste Water Loss of material External Surfaces VII.E5.AP-278 3.3.1.095 E, 1 Steel (Int) Monitoring of Mechanical VII.E5.A-411 3.3.1.135 A Components (B2.1.21)

ULNRC-06057 December 20, 2013 Page 60 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to add LR-ISG-2012-02 aging evaluation lines for identification of components with the potential for corrosion under insulation.

Table 3.3.2-28 (Pages 3.3-273 and 3.3-275) is revised as follows (new text underlined):

Table 3.3.2-28 Auxiliary Systems - Summary of Aging Management Evaluation - Miscellaneous Systems in Scope for Criterion 10 CFR 54.4.(a)(2) - Central Chilled Water System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping LBS Carbon Steel Condensation Loss of material External Surfaces VII.I.A-405 3.3.1.132 A (Ext) and cracking Monitoring of Mechanical Components (B2.1.21)

Table 3.3.2-28 Auxiliary Systems - Summary of Aging Management Evaluation - Miscellaneous Systems in Scope for Criterion 10 CFR 54.4.(a)(2) - Domestic Water System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping LBS Copper Alloy Condensation Loss of material External Surfaces VII.I.A-405 3.3.1.132 A (Ext) and cracking Monitoring of Mechanical Components (B2.1.21)

ULNRC-06057 December 20, 2013 Page 61 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to Section 3.4.2.1, Materials, Environments, Aging Effects Requiring Management and Aging Management Programs (AMPs), as a result of LR-ISG-2012-02 changes.

Section 3.4.2.1 in Chapter V of NUREG-1801 for Steam and Power Conversion System, (Page 3.4-2 thru 3.4-9) is revised to add the materials, environments, aging effects requiring management and (AMPs) to the sections indicated.

3.4.2.1 Materials, Environments, Aging Effects Requiring Management and Aging Management Programs (AMPs)

Loss of Material and Cracking 3.4.2.1.2 Main Steam Supply System 3.4.2.1.3 Main Feedwater System 3.4.2.1.6 Condensate Storage and Transfer System Reduced Thermal Insulation Resistance 3.4.2.1.2 Main Steam Supply System 3.4.2.1.3 Main Feedwater System 3.4.2.1.5 Auxiliary Feedwater System 3.4.2.1.6 Condensate Storage and Transfer System

ULNRC-06057 December 20, 2013 Page 62 of 136 Callaway Plant License Renewal Application Amendment 28 Add a new section for the further evaluation for loss of material due to recurring internal corrosion.

Further Evaluation 3.4.2.2.6 (Page 3.4-10) is added as follows (new text shown underlined):

3.4.2.2.6 Loss of Material Due to Recurring Internal Corrosion Operating experience associated with Steam and Power Conversion System and associated aging management programs does not meet the threshold for significance of aging effect or frequency of occurrence of the aging effect to be considered as recurring internal corrosion.

ULNRC-06057 December 20, 2013 Page 63 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to incorporate LR-ISG-2012-02 changes for aboveground metallic tanks and corrosion under insulation, Table 3.4-1, Summary of Aging Management Programs in Chapter VIII of NUREG-1801 for Steam and Power Conversion System, (Page 3.4-15, 3.4-16, 3.4-21, 3.4-22, and 3.4-31) is revised as follows (deleted text shown in strikethrough and new text shown underlined):

Table 3.4-1 Summary of Aging Management Programs in Chapter VIII of NUREG-1801 for Steam and Power Conversion System Item Component Type Aging Effect / Mechanism Aging Management Further Evaluation Discussion Number Program Recommended 3.4.1.012 Steel; stainless steel Loss of material due to Water Chemistry (B2.1.2) No Consistent with NUREG-1801.

Tanks exposed to general (steel only), pitting, and One-Time Inspection Not applicable. Callaway has no Treated water and crevice corrosion (B2.1.18) in-scope steel or stainless steel tanks less than 100,000 gallons exposed to treated water in the steam and power conversion systems, so the applicable NUREG-1801 lines were not used.

3.4.1.015 Steel Heat exchanger Loss of material due to Water Chemistry (B2.1.2) No Consistent with NUREG-1801.

components exposed general, pitting, crevice, and and One-Time Inspection Not applicable. Callaway has no to Treated water galvanic corrosion (B2.1.18) in-scope steel heat exchanger in the steam and power conversion systems, so the applicable NUREG-1801 lines were not used.

ULNRC-06057 December 20, 2013 Page 64 of 136 Table 3.4-1 Summary of Aging Management Programs in Chapter VIII of NUREG-1801 for Steam and Power Conversion System Item Component Type Aging Effect / Mechanism Aging Management Further Evaluation Discussion Number Program Recommended 3.4.1.030 Steel, Stainless Steel, Loss of material due to Aboveground Metallic No Consistent with NUREG-1801 with Aluminum Tanks general (steel only), pitting, Tanks (B2.1.15) aging management program (within the scope of and crevice corrosion; exceptions.

Chapter XI.M29, cracking due to stress The aging management Aboveground Metallic corrosion cracking (stainless program(s) with exceptions to Tanks) exposed to steel and aluminum only) NUREG-1801 include:

Soil or Concrete, or Aboveground Metallic Tanks the following external (B2.1.15) environments air-outdoor, air-indoor uncontrolled, moist air, condensation 3.4.1.031 Stainless steel, Loss of material due to Aboveground Metallic No Consistent with NUREG-1801 with Aluminum Tanks pitting, and crevice Tanks (B2.1.15) aging management program (within the scope of corrosion; cracking due to exceptions.

Chapter XI.M29, stress corrosion cracking The aging management Aboveground Metallic program(s) with exceptions to Tanks) exposed to NUREG-1801 include:

Soil or Concrete, or Aboveground Metallic Tanks the following external (B2.1.15).

environments air-outdoor, air-indoor uncontrolled, moist air, condensation

ULNRC-06057 December 20, 2013 Page 65 of 136 Table 3.4-1 Summary of Aging Management Programs in Chapter VIII of NUREG-1801 for Steam and Power Conversion System Item Component Type Aging Effect / Mechanism Aging Management Further Evaluation Discussion Number Program Recommended 3.4.061 Metallic piping, piping Loss of material due to A plant-specific aging Yes, plant-specific Not applicable. Callaway has no components, and tanks recurring internal corrosion management program is (See subsection in-scope components subject to exposed to raw water to be evaluated to 3.4.2.2.6) recurring internal corrosion in the or waste water address recurring steam and power conversion internal corrosion systems, so the applicable NUREG-1801 lines were not used.

3.4.062 Steel, stainless steel or Loss of material due to Aboveground Metallic No Consistent with NUREG-1801.

aluminum tanks (within general (steel only), pitting, Tanks (B2.1.15) the scope of Chapter and crevice corrosion XI.M29, Aboveground Metallic Tanks) exposed to treated water 3.4.063 Insulated steel, Loss of material due to External Surfaces No Consistent with NUREG-1801.

stainless steel, copper general (steel, and copper Monitoring of Mechanical alloy, aluminum, or alloy), pitting, or crevice Components (B2.1.21) or copper alloy (> 15% corrosion, and cracking due Aboveground Metallic Zn) piping, piping to stress corrosion cracking Tanks (B2.1.15) (for components, and tanks (aluminum, stainless steel tanks only) exposed to and copper alloy (>15% Zn) condensation, air- only) outdoor

ULNRC-06057 December 20, 2013 Page 66 of 136 Table 3.4-1 Summary of Aging Management Programs in Chapter VIII of NUREG-1801 for Steam and Power Conversion System Item Component Type Aging Effect / Mechanism Aging Management Further Evaluation Discussion Number Program Recommended 3.4.064 Jacketed calcium Reduced thermal insulation External Surfaces No Consistent with NUREG-1801 silicate or fiberglass resistance due to moisture Monitoring of Mechanical insulation in an air- intrusion Components (B2.1.21) indoor uncontrolled or air-outdoor environment 3.4.065 Jacketed foamglas Reduced thermal insulation External Surfaces No Consistent with NUREG-1801 for (glass dust) insulation resistance due to moisture Monitoring of Mechanical material, environment, and aging in an air-indoor intrusion Components (B2.1.21) effect, but a different aging uncontrolled or air- management program outdoor environment Aboveground Metallic Tanks (B2.1.15) is credited.

ULNRC-06057 December 20, 2013 Page 67 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to add LR-ISG-2012-02 aging evaluation lines for insulated piping and revise the aging evaluation for calcium silicate insulation.

Table 3.4.2-2 (Pages 3.4-34 and 3.3-40) is revised as follows (deleted text shown in strikethrough and new text shown underlined):

Table 3.4.2-2 Steam and Power Conversion System - Summary of Aging Management Evaluation - Main Steam Supply System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Insulation INS Insulation Plant Indoor Air None None None None J, 2 Calcium (Ext) Reduced External Surfaces VIII.I.S-403 3.4.1.064 A Silicate thermal Monitoring of Mechanical insulation Components (B2.1.21) resistance Piping LBS, SIA Carbon Steel Condensation Loss of External Surfaces VIII.B1.S-402 3.4.1.063 A (Ext) material and Monitoring of Mechanical cracking Components (B2.1.21)

ULNRC-06057 December 20, 2013 Page 68 of 136 Notes for Table 3.4.2-2:

Standard Notes:

A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

D Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

E Consistent with NUREG-1801 for material, environment, and aging effect, but a different aging management program is credited or NUREG-1801 identifies a plant-specific aging management program.

J Neither the component nor the material and environment combination is evaluated in NUREG-1801.

Plant Specific Notes:

1 NUREG-1801,Section XI.M24 Compressed Air Monitoring applies to monitoring the piping and components associated with the air compressors and dryers. Air compressor and dryer piping and components are not within the scope of license renewal for Callaway. In-scope piping and components are associated with containment penetrations and nitrogen gas piping and components for backup closure of valves. The AMP M38 Internal Surfaces in Miscellaneous Piping and Ducting Components requires internal inspections consistent with the AMP M24 Compressed Air Monitoring. Therefore, for components associated with the compressed air system, the AMP M38 Internal Surfaces in Miscellaneous Piping and Ducting Components is credited rather than M24 Compressed Air Monitoring.

2 Based on plant operating experience, there are no aging effects requiring management for calcium silicate insulation in a metal jacket in a plant indoor air environment. The insulation does not experience aging effects unless exposed to temperatures, radiation, or chemicals capable of attacking the specific chemical composition of the insulation. The insulation is contained in metal jacket with a vapor barrier to prevent moisture intrusion and is in a non-aggressive air environment that does not experience significant aging effects.

ULNRC-06057 December 20, 2013 Page 69 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to add LR-ISG-2012-02 aging evaluation lines for insulated piping and revise the aging evaluation for calcium silicate insulation.

Table 3.4.2-3 (Pages 3.4-42, and 3.4-46) is revised as follows (deleted text shown in strikethrough and new text shown underlined):

Table 3.4.2-3 Steam and Power Conversion System - Summary of Aging Management Evaluation - Main Feedwater System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Insulation INS Insulation Plant Indoor Air None None None None J, 1 Calcium (Ext) Reduced External Surfaces VIII.I.S-403 3.4.1.064 A Silicate thermal Monitoring of Mechanical insulation Components (B2.1.21) resistance Piping LBS Carbon Steel Condensation Loss of External Surfaces VIII.D1.S-402 3.4.1.063 A (Ext) material and Monitoring of Mechanical cracking Components (B2.1.21)

ULNRC-06057 December 20, 2013 Page 70 of 136 Notes for Table 3.4.2-3:

Standard Notes:

A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

J Neither the component nor the material and environment combination is evaluated in NUREG-1801.

Plant Specific Notes:

None 1 Based on plant operating experience, there are no aging effects requiring management for calcium silicate insulation in a metal jacket in a plant indoor air environment. The insulation does not experience aging effects unless exposed to temperatures, radiation, or chemicals capable of attacking the specific chemical composition of the insulation. The insulation is contained in metal jacket with a vapor barrier to prevent moisture intrusion and is in a non-aggressive air environment that does not experience significant aging effects.

ULNRC-06057 December 20, 2013 Page 71 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to add LR-ISG-2012-02 aging evaluation lines to revise the aging evaluation for calcium silicate insulation.

Table 3.4.2-5 (Pages 3.4-54 and 3.4-60) is revised as follows (deleted text shown in strikethrough and new text shown underlined):

Table 3.4.2-5 Steam and Power Conversion System - Summary of Aging Management Evaluation - Auxiliary Feedwater System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Insulation INS Insulation Plant Indoor Air None None None None J, 1 Calcium (Ext) Reduced External Surfaces VIII.I.S-403 3.4.1.064 A Silicate thermal Monitoring of Mechanical insulation Components (B2.1.21) resistance

ULNRC-06057 December 20, 2013 Page 72 of 136 Notes for Table 3.4.2-5:

Standard Notes:

A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

D Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP G Environment not in NUREG-1801 for this component and material.

J Neither the component nor the material and environment combination is evaluated in NUREG-1801.

Plant Specific Notes:

None 1 Based on plant operating experience, there are no aging effects requiring management for calcium silicate insulation in a metal jacket in a plant indoor air environment. The insulation does not experience aging effects unless exposed to temperatures, radiation, or chemicals capable of attacking the specific chemical composition of the insulation. The insulation is contained in metal jacket with a vapor barrier to prevent moisture intrusion and is in a non-aggressive air environment that does not experience significant aging effects.

ULNRC-06057 December 20, 2013 Page 73 of 136 Callaway Plant License Renewal Application Amendment 28 Changes made to add LR-ISG-2012-02 aging evaluation lines for insulated piping and revise the aging evaluation for aboveground metallic tanks and calcium silicate insulation.

Table 3.4.2-6 (Pages 3.4-62, 3.4-63, and 3.3-65) is revised as follows (deleted text shown in strikethrough and new text shown underlined):

Table 3.4.2-6 Steam and Power Conversion System - Summary of Aging Management Evaluation - Condensate Storage and Transfer System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Insulation INS Acrylic/Ureth Atmosphere/ Cracking, Aboveground Metallic None None J, 3 1 ane Weather (Ext) blistering, Tanks (B2.1.15) change in color Insulation INS Insulation Atmosphere/ None None None None J, 2 Foamglas Weather Reduced Aboveground Metallic VIII.I.S-404 3.4.1.065 E,2 (glass dust) (External) thermal Tanks (B2.1.15) insulation resistance Piping PB Carbon Steel Condensation Loss of External Surfaces VIII.H.S-402 3.4.1.063 A (Ext) material and Monitoring of Mechanical cracking Components (B2.1.21)

ULNRC-06057 December 20, 2013 Page 74 of 136 Table 3.4.2-6 Steam and Power Conversion System - Summary of Aging Management Evaluation - Condensate Storage and Transfer System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Tank PB Stainless Atmosphere/ Cracking Loss Aboveground Metallic VIII.G.SP-118 3.4.1.002 E, 1 Steel Weather (Ext) of material and Tanks (B2.1.15) VIII.E.SP-138 3.4.1.030 A Cracking Tank PB Stainless Atmosphere/ Loss of Aboveground Metallic VIII.G.SP-127 3.4.1.003 E, 1 Steel Weather (Ext) material Tanks (B2.1.15)

Tank PB Stainless Concrete (Ext) Loss of Aboveground Metallic VIII.E.SP-137 3.4.1.031 B Steel material and Tanks (B2.1.15) A Cracking Tank PB Stainless Condensation Loss of Inspection of Internal V.D1.EP-81 3.2.1.048 D Steel (Int) material Surfaces in Miscellaneous Piping and Ducting Components (B2.1.23)

Tank PB Stainless Secondary Loss of Water Chemistry (B2.1.2) VIII.G.SP-75 3.4.1.012 A Steel Water (Int) material and One-Time Inspection VIII.E.S-405 3.4.1.062 (B2.1.18) Aboveground Metallic Tanks (B2.1.15)

ULNRC-06057 December 20, 2013 Page 75 of 136 Notes for Table 3.4.2-6:

Standard Notes:

A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

D Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

E Consistent with NUREG-1801 for material, environment, and aging effect, but a different aging management program is credited or NUREG-1801 identifies a plant-specific aging management program.

J Neither the component nor the material and environment combination is evaluated in NUREG-1801.

Plant Specific Notes:

1 The bottom of this tank rests on a concrete foundation. Therefore the Aboveground Metallic Tanks program (B2.1.15) is credited.

2 The mechanical properties FOAMGLAS (glass dust) are consistent with other glass materials and is evaluated consistent with other glass-like materials in an atmosphere/weather environment in NUREG-1801.

31 Acrylic/Urethane in an Atmosphere/Weather (Ext.) environment is subjected to UV radiation, moisture and thermal exposure. The acrylic rubber sealant coating provides UV radiation protection for the urethane foam tank insulation. The dome of the stainless steel tank is prepped with a low halogen (<200 ppm) primer prior to the application of the foam urethane. The Aboveground Metallic Tanks program (B2.1.15) manages cracking blistering or changes in color of the acrylic/urethane insulation. The acrylic rubber sealant is inspected for aging and damage as an indicator for the urethane foam underneath it.

2. The Aboveground Metallic Tanks program (B2.1.15) is used instead of the External Surfaces Monitoring of Mechanical Components program (B2.1.21) to manage Foamglas insulation on the condensate storage tank.

ULNRC-06057 December 20, 2013 Enclosure 2 Page 76 of 136 Callaway Plant License Renewal Application Amendment 28 Reactor vessel studs usage factors in the Reactor Pressure Vessel Section of Table 4.3-3 were revised to reflect the results of the license renewal analysis to address the stuck stud. In addition, the accumulator piping usage factor in the Class 1 Piping Section of Table 4.3-3 was revised to reflect the recent modification for the addition of a tie-back support.

Table 4.3-3 Reactor vessel studs usage factors in the Reactor Pressure Vessel Section (Page 4.3-19) and the accumulator piping usage factor in the Class 1 Piping Section (Page 4.3-22) are revised as follows (new text underlined and deleted text shown in strikethrough):

Table 4.3-3 ASME Class 1 Fatigue Analyses Under the Fatigue Monitoring Program Component CUF Reactor Pressure Vessel Components Inlet Nozzles 0.0795 Support 0.0306 Outlet Nozzles 0.1078 Support 0.0205 Head Flanges 0.0155 Vessel Flange 0.0196 Studs 0.47800.63 Studs Installed in Holes with Damaged Threads 0.750.99 CRDM Housing 0.1093 Bottom Head to Shell Junction 0.0070 Bottom-Mounted Instrument Tubes 0.3184 Vessel Wall Transition 0.0105 Core Support Lugs 0.0617 Head Adapter Plug 0.0036

ULNRC-06057 December 20, 2013 Enclosure 2 Page 77 of 136 Class 1 Piping 0.099 Pressurizer Surge Line Includes the effects of thermal stratification.

Spray/Aux. Spray Loops 1 & 2 0.84 Pressurizer Safety Valve Piping 0.975 Pressurizer Relief Valve Piping 0.970 Hot Leg 0.95 Crossover Leg 0.50 Cold Leg 0.37 Drain Line Loop 2 0.95 Normal Letdown/Drain Line Loop 3 0.95 Drain Line Loop 1 0.01 Excess Letdown/Drain Line Loop 4 0.191 Normal/Alternate Charging - Loops 1 & 4 0.93 Seal Water Injection Loop 1 0.066 Seal Water Injection Loop 2 0.066 Seal Water Injection Loop 3 0.114 Seal Water Injection Loop 4 0.067 RHR Loops 1 & 4 Suction Line 0.296 Loop 1 Hot Leg Safety Injection Line 0.661 Loop 4 Hot Leg Safety Injection Line 0.110 0.980 Accumulator Lines - Loops 1, 2, 3, & 4 0.999 (Loop 4)

SI Hot Leg Loops 2 & 3 0.090 Boron Injection Header 0.773 Boron Injection Header Lines - Loops 1, 2, 3, & 4 0.930

ULNRC-06057 December 20, 2013 Page 78 of 136 Appendix A Final Safety Analysis Report Supplement A1.6 PWR VESSEL INTERNALS The PWR Vessel Internals program relies on implementation of the guidance included in Electric Power Research Institute (EPRI) 1022863 (MRP-227-A), PWR Internals Inspection and Evaluation Guideline and EPRI 1016609 (MRP-228), Inspection Standard for PWR Internals to manage the aging effects of reactor vessel internal (RVI) components.

This program is used to manage (a) various forms of cracking, including stress corrosion cracking (SCC), primary water stress corrosion cracking (PWSCC), irradiation assisted stress corrosion cracking (IASCC), or cracking due to fatigue/cyclical loading; (b) loss of material induced by wear; (c) loss of fracture toughness due to either thermal aging or neutron irradiation embrittlement; (d) changes in dimension due to void swelling and irradiation growth; and (e) loss of preload due to thermal and irradiation-enhanced stress relaxation or creep.

The PWR Vessel Internals program is a new program and will be implemented within 24 months after the issuance of MRP-227-A, PWR Internals Inspection and Evaluation Guideline.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

Callaway Plant Unit 1 Page A-4 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 79 of 136 Appendix A Final Safety Analysis Report Supplement A1.10 OPEN-CYCLE COOLING WATER SYSTEM The Open-Cycle Cooling Water System program manages loss of material, wall thinning, reduction of heat transfer, cracking, blistering, change in color, and hardening and loss of strength for components within the scope of license renewal and exposed to the raw water of the essential service water system and heat exchangers and other components in other systems serviced by the essential service water system.

The program is consistent with commitments as established in responses to NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Components and includes:

(a) surveillance and control of biofouling, (b) tests to verify heat transfer, (c) routine inspection and maintenance program, (d) system walkdown inspection, and (e) review of maintenance, operating, and training practices and procedures.

The Open-Cycle Cooling Water System program includes the essential service water system that transfers heat from the safety-related structures, systems and components to the ultimate heat sink as defined in NRC Generic Letter 89-13. Periodic heat transfer testing or inspection and cleaning of heat exchangers with a heat transfer intended function is performed in accordance with commitments to NRC Generic Letter 89-13 to verify heat transfer capabilities.

In addition, the internal coatings of components within the scope of this program are periodically visually inspected to ensure that loss of coating integrity is detected prior to (1) loss of component intended function, including loss of function due to accelerated degradation caused by localized coating failures, and (2) degradation of downstream component performance due to flow blockage.

Callaway Plant Unit 1 Page A-7 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 80 of 136 Appendix A Final Safety Analysis Report Supplement A1.14 FIRE WATER SYSTEM The Fire Water System program manages loss of material and flow blockage for water-based fire protection systems. Consistent with National Fire Protection Association (NFPA) commitments, the program consists of periodic full-flow flush tests and system performance tests to prevent corrosion from biofouling in the fire protection system.

This program manages aging effects through the use of flow testing and visual inspections performed consistent with provisions of the 2011 Edition of National Fire Protection Association (NFPA) 25 noted in Table A1.14-1. Unless noted in Table A1.14-1, flow testing and visual inspections are performed at intervals specified in the 2011 Edition of NFPA 25. Testing or replacement of sprinklers that have been in place for 50 years is performed in accordance with the 2011 Edition of NFPA 25.

In addition to NFPA codes and standards, portions of the water-based fire protection system that are: (a) normally dry but periodically subjected to flow (e.g., dry-pipe or preaction sprinkler system components) and (b) cannot be drained or allow water to collect are to be subjected to augmented testing beyond that specified in NFPA 25, including (a) periodic full flow tests at the design pressure and flow rate or internal visual inspections and (b) volumetric wall-thickness examinations.

The water-based fire protection system is normally maintained at required operating pressure and is monitored such that loss of system pressure is immediately detected and corrective actions initiated.

The Fire Water System program conducts flow tests through each open head spray/sprinkler nozzle to verify water flow is unobstructed. Prior to 50 years in service, the Fire Water System program requires sprinkler heads to be replaced or have representative samples submitted for field-service testing by a recognized testing laboratory in accordance with NFPA 25. The program field-service tests additional representative samples every 10 years thereafter during the period of extended operation to ensure signs of aging are detected in a timely manner.

Non-intrusive wall thickness examinations are performed on fire water piping to identify loss of material. Wall thickness examinations will be performed on fire water piping every three years. Each three year sample will include at least three locations for a total of 100 feet of above-ground fire water piping and be selected based on system susceptibility to corrosion or fouling and evidence of performance degradation during system flow testing or periodic flushes. The basis for the frequency is that three years is the frequency required by the FSAR for the yard fire loop flush and for the flow tests of the fire water loops. In addition internal Internal visual internal inspections are used when the internal surface of the piping is exposed during plant maintenance. These inspections evaluate (a) wall thickness to ensure against catastrophic failure and (b) the inner diameter of the piping as it applies to the design flow of the fire protection system.

Callaway Plant Unit 1 Page A-8 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 81 of 136 Appendix A Final Safety Analysis Report Supplement Samples are collected for microbiologically-influenced corrosion quarterly and when fire water piping and components are opened for maintenance or are accessible. Biofouling is prevented by periodically adding treatment chemicals such as an anti-scalant, a biopenetrant, and a biostat to the fire water system annually and when monitoring indicates they should be added. The MIC Index is trended to evaluate treatment effectiveness in specific locations.

Inspections of wetted normally dry piping segments that cannot be drained or that allow water to collect begin five years before the period of extended operation. The program's remaining inspections begin during the period of extended operation.

The internal coating of the fire water storage tanks will be inspected with a minimum frequency of alternating refueling outages.

Table A1.14-1 Fire Water System Aging Management NFPA 25 Component Aging Management Performed Section Sprinkler 5.2.1.1 Sprinklers are inspected for signs of leakage, corrosion, Systems: and foreign material.

Sprinkler inspections Sprinkler 5.3.1 Prior to 50 years in service, the Fire Water System Systems: program requires sprinkler heads to be replaced or have Sprinkler testing representative samples submitted for field-service testing by a recognized testing laboratory in accordance with NFPA 25. The program field-service tests additional representative samples every 10 years thereafter during the period of extended operation to ensure signs of aging are detected in a timely manner.

Standpipe and 6.3.1 Flow testing is conducted at least every five years at the Hose Systems: hydraulically most remote hose connections of each Flow Tests zone of an automatic standpipe system to verify the water supply provides the design pressure at the required flow.

Private Fire 7.3.1 Underground and exposed piping is flow tested at flows Service Mains: representative of those during a fire to determine the Underground internal condition of the piping at minimum 3-year and Exposed intervals.

Piping Private Fire 7.3.2 Hydrants are flow tested annually to ensure proper Service Mains: functioning.

Hydrants Callaway Plant Unit 1 Page A-9 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 82 of 136 Appendix A Final Safety Analysis Report Supplement NFPA 25 Component Aging Management Performed Section Fire Pumps: 8.3.3.7 Not applicable. Callaway's fire protection pumps do not Suction Screens have suction screens.

Water Storage 9.2.5.5 The exterior painted surface of the fire water storage Tanks: Exterior tanks (FWSTs) is inspected annually for signs of Inspections degradation.

Water Storage 9.2.6, The interior of each FWST is inspected every other Tanks: Interior 9.2.7 refueling cycle for signs of aging. Testing of interior inspections surfaces is performed for coating integrity and tank bottom integrity when FWSTs exhibit signs of interior pitting, corrosion, or coating failure.

Valves and 13.2.5 Main drain tests are not conducted at Callaway. As an System-Wide alternative, one of the following methods is used to Testing: Main assure the reliable operation of the fire protection water Drain Test supply system.

1. The fire suppression system is fed from two or more directions such that the failure of one isolation valve will not impair the system and the long runs of pipe are flow tested under other surveillances.

OR

2. The flow path from the fire pump to the system control valve is verified on an 18-month frequency, and the following surveillances are performed with acceptable results:

• Fire water valve position verification

• Fire protection valve cycling

• Annual fire protection loop flow test

• Fire protection water system flush

• Hydrant flush

• Post indicator valve testing

• Wet pipe, deluge, and preaction system visual inspection Valves and 13.4.3.2.2 A full flow test using air or water is performed every System-Wide to refueling outage by trip testing each deluge valve to Testing: Deluge 13.4.3.2.5 verify that spray/sprinkler nozzles are unobstructed.

Valves Callaway Plant Unit 1 Page A-10 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 83 of 136 Appendix A Final Safety Analysis Report Supplement NFPA 25 Component Aging Management Performed Section Water Spray 10.2.1.6, Spray system strainers are inspected and cleaned every Fixed Systems: 10.2.1.7, refueling outage and after each system actuation.

Strainers 10.2.7 Callaway does not have main line strainers.

Water Spray 10.3.4.3 A full flow test is performed every refueling cycle using Fixed Systems: air or water to verify that spray/sprinkler nozzles are Operation Test unobstructed.

Foam Water 11.2.7.1 Not applicable. Callaway does not have a foam water Sprinkler sprinkler system.

Systems:

Strainers Foam Water 11.3.2.6 Not applicable. Callaway does not have a foam water Sprinkler sprinkler system.

Systems:

Operational Test Discharge Patterns Foam Water Visual Not applicable. Callaway does not have a foam water Sprinkler inspection sprinkler system.

Systems: for Storage tanks internal corrosion Obstruction 14.2 and The internal surface of piping and branch lines is Investigation: 14.3 inspected for foreign material every five years by flushing Obstruction, wet pipe system piping. In buildings having multiple wet Internal pipe systems, every other system is inspected every five Inspection of years, and the remaining systems are inspected at the Piping next five year interval. If foreign material is found in any system in a building during the five year inspection, then all systems in the building will be inspected.

If sufficient foreign material is found to obstruct pipe or sprinklers, then an obstruction investigation is conducted. If the visual inspection detects surface irregularities that could indicate wall loss below nominal pipe wall thickness, then follow-up volumetric examinations will be performed.

Callaway Plant Unit 1 Page A-11 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 84 of 136 Appendix A Final Safety Analysis Report Supplement A1.15 ABOVEGROUND METALLIC TANKS The Aboveground Metallic Tanks program manages loss of material and cracking on the external surfaces of aboveground metallic tanks within the scope of license renewal that are supported on concrete or soil. The program also manages cracking, blistering, and change in color of the acrylic/urethane insulation on the condensate storage tank (CST).

The program applies to the CST, and refueling water storage tank (RWST). and the two fire water storage tanks (FWSTs).

For the carbon steel fire water storage tanks, the program relies on application of paint, coating, or tank bottom edge grout as corrosion preventive measures. In addition, cathodic protection is used as a preventive measure to prevent corrosion on exposed bare metal as-left surfaces of the tanks.

This program performs visual inspections during each refueling cycle to monitor for aging of the tank wall and dome external surface paint or damage of the external surface insulation covering. A one-time inspection of twenty-five external surface locations of approximately one square foot in area will be inspected by removing insulation, with at least ten locations near the base of the tank wall and at least two locations on the dome.

Removal of the tank insulation permits a sampling visual and surface examinations of the tank external surfaces to be inspected for aging confirm that environmental impacts are not present at sufficient levels to cause pitting corrosion, crevice corrosion or cracking.

One-time volumetric examinations thickness measurements are taken within five years prior to entering the period of extended operation from inside the emptied tanks to determine the thickness of the tank bottom. The entire tank bottom will be scanned to detect loss of material. Thickness measurements will be performed on regions of the tank bottom that indicate a loss of material below nominal plate thickness. The thickness measurements ensure significant loss of material is not occurring, so that the intended function of each tank is maintained during the period of extended operation. A soil sample is taken underneath the CST and RWST and analyzed to demonstrate that the soil is not corrosive The soil sample is performed prior to entering the period of extended operation and during each ten-year period in the period of extended operation.

The chemical treatments of cooling tower water do not contain chemical compounds that could cause cracking, pitting, or crevice corrosion on the external surfaces of the tanks.

Within five years of Prior to entering the period of extended operation and during each ten year period in the period of extended operation, a one-time soil surface sample near the CST and RWST will be performed. The soil surface sample and samples of residue on the top and sides of each tank will be evaluated to ensure that chlorides or other aggressive cooling tower water treatment chemicals are not creating an aggressive environment that would degrade the CST, RWST, or their insulation jacketing.

Callaway Plant Unit 1 Page A-8 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 85 of 136 Appendix A Final Safety Analysis Report Supplement A one-time inspection consistent with the One-Time Inspection program (A1.18) will be performed on the inside surfaces of the CST and RWST shell, roof and bottom.

The Aboveground Metallic Tanks program is a new program that will be implemented within the five year period prior to the period of extended operation.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

Callaway Plant Unit 1 Page A-9 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 86 of 136 Appendix A Final Safety Analysis Report Supplement A1.21 EXTERNAL SURFACES MONITORING OF MECHANICAL COMPONENTS The External Surfaces Monitoring of Mechanical Components program manages loss of material and cracking for metallic components and cracking and changes in material properties for cement board components. The program also manages loss of material, cracking, and hardening and loss of strength for polymeric components. Periodic visual inspections of external surfaces conducted through engineering walkdowns will be used to identify loss of material and leakage. A sample of outdoor component surfaces that are insulated and a sample of indoor insulated components exposed to condensation (due to the in-scope component being operated below the dew point), are periodically inspected every 10 years during the period of extended operation. Periodic polymeric inspections will also include manual or physical manipulation in order to verify the absence of cracking, hardening, or loss of strength. Periodic monitoring of stainless steel components will also include visual inspection for cracking when exposed to an air environment containing halides.

The External Surfaces Monitoring of Mechanical Components program is a new program that will be implemented prior to the period of extended operation.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

Callaway Plant Unit 1 Page A-12 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 87 of 136 Appendix A Final Safety Analysis Report Supplement A1.23 INSPECTION OF INTERNAL SURFACES IN MISCELLANEOUS PIPING AND DUCTING COMPONENTS The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program manages cracking, loss of material, hardening and loss of strength. The program inspects internal surfaces of metallic piping, piping components, ducting, polymeric components, and other components that are exposed to plant indoor air, ventilation atmosphere, atmosphere/weather, condensation, borated water leakage, diesel exhaust, lubricating oil, and water system environment not managed by Open-Cycle Cooling Water System (A1.10),

Closed Treated Water System (A1.11), Fire Water System (A1.14), and Water Chemistry (A1.2) programs.

Internal inspections are normally performed at opportunities where the internal surfaces are made accessible, such as periodic system and component surveillance activities or maintenance activities. Visual inspections of internal surfaces of plant components are performed by qualified personnel. For certain materials, such as polymers, visual inspections will be augmented by physical manipulation or pressurization to detect hardening, loss of strength, and cracking. The program includes inspections to detect material degradation that could result in a loss of component intended function.

If work opportunities are not sufficient to allow inspection of a representative sample of components, supplemental inspections are also performed. A representative sample size is 20 percent of the accessible and inaccessible component population (defined as components having the same material and environment combination) up to a maximum of 25 components.

The locations and intervals for supplemental inspections are based on assessments of the likelihood of significant aging effects, derived from current industry and plant-specific operating experience.

Components having the same material-environment combination with repetitive failures due to aging require a plant-specific program, unless the component material has been replaced by a material of more corrosion resistance for the environment of interest.

In addition, the internal coatings of the service water pump strainers are periodically visually inspected to ensure that loss of coating integrity is detected prior to (1) loss of component intended function, including loss of function due to accelerated degradation caused by localized coating failures, and (2) degradation of downstream component performance due to flow blockage.

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program is a new program and will be implemented prior to the period of extended operation.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

Callaway Plant Unit 1 Page A-13 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 88 of 136 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments LRA Implementation Item # Commitment Section Schedule 4 Implement the PWR Vessel Internals program as described in LRA Section B2.1.6. As part of B2.1.6 PWR Vessel the implementation activities address the following Applicant/Licensee Action Items (A/LAI) of Internals program NRC MRP-227-A Safety Evaluation dated December 16, 2011. (Completed LRA Amendment implementation and

28) A/LAI #1:

Within 24 months Applicant/Licensee Action Item (A/LAI) #1 after the issuance of MRP-227-A, PWR Each applicant/licensee is responsible for assessing its plants design and operating Internals Inspection history and demonstrating that the approved version of MRP-227 is applicable to the and Evaluation facility. Each applicant/licensee shall refer, in particular, to the assumptions regarding Guideline plant design and operating history made in the FMECA and functionality analyses for Completed.

reactors of their design (i.e., Westinghouse, CE, or B&W) which support MRP-227 and describe the process used for determining plant-specific differences in the design of their RVI components or plant operating conditions, which result in different component inspection categories. The applicant/licensee shall submit this evaluation for NRC review and approval as part of its application to implement the approved version of MRP-227. (Completed LRA Amendment 28)

Applicant/Licensee Action Item (A/LAI) #8 Item #5 (in part - reactor coolant system water environment portion)

Enhance the Fatigue Monitoring program to evaluate the effects of the reactor coolant system water environment on the reactor vessel internal components with existing fatigue CUF analyses to satisfy the evaluation requirements of ASME Code,Section III, Subsection NG-2160 and NG-3121. (moved to item 31)

Callaway Plant Unit 1 Page A-37 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 89 of 136 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments LRA Implementation Item # Commitment Section Schedule 6 Enhance the Open-Cycle Cooling Water System program procedures to: B2.1.10 Completed no later

• include polymeric material inspection requirements, parameters monitored, and than six months prior acceptance criteria. Examination of polymeric materials by OCCW System program will to the PEO.

be consistent with examinations described in the Inspection of Internal Surfaces in Inspections and Miscellaneous Piping and Ducting Components program. testing to be

• inspect the essential service water strainers for coating degradation. completed no later

• include inspection and cleaning, if necessary, of the air-side of safety-related air-to- than six months prior water heat exchangers cooled by essential service water. to the PEO or the end

• inspect for coating detachment indications that affect downstream components during of the last refueling internal coatings inspections and specify acceptance criteria for coating detachment outage prior to the indications. Coatings detachments that are not repaired or removed to leave sound PEO, whichever coating bonded to the surface will be evaluated to confirm coating manufacturer occurs later.

installation requirements, tested using techniques identified in ASTM-D7167 to confirm if the coating is bonded to the surface, and trended.

• perform periodic visual inspections of the internal coatings of components within the scope of this program to ensure that loss of coating integrity is detected prior to (1) loss of component intended function, including loss of function due to accelerated degradation caused by localized coating failures, and (2) degradation of downstream component performance due to flow blockage. Inspection frequency is based on coating condition. Inspection results will be evaluated by personnel qualified consistent with ASTM D7108-05, Standard Guide for Establishing Qualifications for a Nuclear Coating Specialist, as described in the Protective Coating Monitoring and Maintenance program (B2.1.33). Acceptance criteria will include the following:

1. Peeling and delaminations are not permitted

2. Cracking is not permitted if accompanied by delamination or loss of adhesion.

Callaway Plant Unit 1 Page A-37 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 90 of 136 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments LRA Implementation Item # Commitment Section Schedule

3. Blisters are limited to intact blisters. Testing will be performed confirm that the blisters are completely surrounded by sound coating bonded to the surface.

4. Localized areas of coating degradation without subsequent loss of material of the base metal are considered acceptable if the area is completely surrounded by sound coating bonded to the surface.

• Prior to the period of extended operation, an inspection technique will be selected from available technologies to identify internal pipe wall degradation due to MIC for performance of a one-time inspection of a buried carbon steel piping segment that is representative of other accessible carbon steel ESW piping segments.

Callaway Plant Unit 1 Page A-13 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 91 of 136 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments LRA Implementation Item # Commitment Section Schedule 9 Enhance the Fire Protection program procedures to: B2.1.13 Completed no later

• include visual inspections of the external surfaces of Halon fire suppression system than six months prior components for excessive loss of material due to corrosion. (Completed LRA to the PEO.

Amendment 28) Inspections and

• include trending of the performance of the Halon system during testing. (Completed testing to be LRA Amendment 1) complete no later than six months prior to PEO or the end of the last refueling outage prior to the PEO, whichever occurs later.

Completed Callaway Plant Unit 1 Page A-38 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 92 of 136 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments LRA Implementation Item # Commitment Section Schedule 10 Recoat the internal surface of fire water storage tanks. B2.1.14 Completed no later than six months prior Enhance the Fire Water System program procedures to: to the PEO.

include non-intrusive pipe wall thickness examinations. Wall thickness examinations Implementation is will be performed on fire water piping to be performed every three years. Each three started five years year sample will include at least three locations for a total of 100 feet of above-ground before the period of fire water piping and be selected based on system susceptibility to corrosion or fouling extended operation.

and evidence of performance degradation during system flow testing or periodic Recoat the internal flushes. In addition, internal Internal inspections will be performed on accessible surface of the fire exposed portions of fire water piping during plant maintenance activities. When visual water storage tanks, inspections are used to detect loss of material, the inspection technique is capable of and, inspections, and detecting surface irregularities that could indicate wall loss to below nominal pipe wall testing of wetted thickness due to corrosion and corrosion product deposition. Where such irregularities segments that cannot are detected, follow-up volumetric wall thickness examinations are performed. Pipe be drained or that wall thickness examinations and internal inspections will be performed commencing allow water to collect after 2014 and throughout the period of extended operation. to be completed no

replace sprinkler heads prior to 50 years in service or have a recognized testing later than six months laboratory field-service test a representative sample in accordance with NFPA 25 and prior to PEO or the test additional samples every 10 years thereafter to ensure signs of aging are detected end of the last in a timely manner. refueling outage prior

review and evaluate trends in flow parameters recorded during the NFPA 25 fire water to the PEO whichever flow tests. occurs later.

perform annual hydrant flow testing in accordance with NFPA 25. The programs

perform annual hydrostatic testing of fire brigade hose. remaining inspections

Inspect the internal surface of piping and branch lines for foreign material every five begin during the years by flushing wet pipe system piping. In buildings having multiple wet pipe period of extended systems, every other system is inspected every five years, and the remaining systems operation.

Callaway Plant Unit 1 Page A-38 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 93 of 136 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments LRA Implementation Item # Commitment Section Schedule are inspected at the next five year interval. If foreign material is found in any system in a building during the five year inspection, then all systems in the building will be inspected. If sufficient foreign material is found to obstruct pipe or sprinklers, then an obstruction investigation is conducted per NFPA 25, Annex D. Visual inspections will include an inspection technique that is capable of detecting surface irregularities due to corrosion and corrosion product deposition. If the visual inspection detects surface irregularities that could indicate wall loss below nominal pipe wall thickness, then follow-up volumetric examinations will be performed.

Perform augmented tests and inspections of water-based fire protection system components that have been wetted but are normally dry. The augmented tests and inspections are conducted as follows on piping segments that cannot be drained or that allow water to collect:

• In each five-year interval, beginning five years prior to the period of extended operation, either conduct a flow test or flush sufficient to detect potential flow blockage, or conduct a visual inspection of 100 percent of the internal surface of piping segments that cannot be drained or allow water to collect.

• A 100% baseline inspection will be performed prior to the period of extended operation. In each five-year interval of the period of extended operation, 20 percent of the length of piping segments that cannot be drained or that allow water to collect is subject to volumetric wall thickness inspections. Measurement points will be obtained to the extent that each potential degraded condition can be identified (e.g., general corrosion, MIC). The 20 percent of piping that is inspected in each five-year interval will be in different locations than previously inspected piping.

If the results of a 100 percent internal visual inspection are acceptable, and the segment is not subsequently wetted, no further augmented tests or inspections will be performed.

Callaway Plant Unit 1 Page A-39 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 94 of 136 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments LRA Implementation Item # Commitment Section Schedule

require the inspection of the interior of the fire water storage tanks to include checking for evidence of voids beneath the floor.

change the frequency of trip testing each deluge valve from every three years to every refueling outage.

change the frequency of tests of spray/sprinkler nozzle discharge patterns from every three years to every refueling outage.

perform the following additional inspections if pitting, corrosion, or coating failure is found during the inspection of the fire water storage tanks: (1) tank coatings are evaluated using an adhesion test consistent with ASTM D 3359, Standard Test Methods for Measuring Adhesion by Tape Test; (2) dry film thickness measurements are taken at random locations to determine the overall coating thickness; (3) nondestructive ultrasonic readings are taken to evaluate the wall thickness where there is evidence of pitting or corrosion; (4) interior surfaces are spot wet-sponge tested to detect pinholes, cracks, or other compromises in the coating; (5) tank bottoms are tested for metal loss on the underside by use of ultrasonic testing where there is evidence of pitting or corrosion; (6) bottom seams are vacuum-box tested in accordance with NFPA 22, Standard for Water Tanks for Private Fire Protection.

Require the removal of foreign material if its presence is found during pipe inspections to obstruct pipe or sprinklers. In addition, the source of the material is determined and corrected.

Callaway Plant Unit 1 Page A-40 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 95 of 136 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments LRA Implementation Item # Commitment Section Schedule 13 Enhance the Reactor Vessel Surveillance program to: B2.1.17 Completed

• determine the vessel fluence by ex-vessel dosimetry, following withdrawal of the final 4.2 Completed no later capsule. (Completed Amendment 28) than six months prior

• require that pulled and tested surveillance capsules are placed in storage for future to the PEO.

reconstitution or reinsertion unless given NRC approval to discard. (Completed Amendment 28)

• specifically require the design change process to evaluate the impact of plant operation changes on reactor vessel embrittlement. (Completed Amendment 14)

Callaway Plant Unit 1 Page A-40 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 96 of 136 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments LRA Implementation Item # Commitment Section Schedule 17 Implement the External Surfaces Monitoring of Mechanical Components program as described B2.1.21 Completed in LRA Section B2.1.21 Implemented no later than six months prior to the PEO. and Inspections to be completed no later than six months prior to PEO or the end of the last refueling outage prior to the PEO, whichever occurs later.

inspections to begin during the period of extended operation.

Callaway Plant Unit 1 Page A-41 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 97 of 136 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments LRA Implementation Item # Commitment Section Schedule 33 As additional industry and plant-specific applicable operating experience becomes available, it B2.1.6 Completed consistent will be evaluated and incorporated into each new program. B2.1.15 with implementation B2.1.18 schedule noted with B2.1.19 each referenced B2.1.20 aging management B2.1.21 program.

B2.1.23 B2.1.25 B2.1.37 B2.1.38 B2.1.39 Callaway Plant Unit 1 Page A-47 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 98 of 136 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments LRA Implementatio Item # Commitment Section n Schedule 34 Callaway Ameren Missouri replacement steam generator divider plate assemblies are Section Between Fall 2025 fabricated of Alloy 690. The divider plate to primary head and tubesheet junctions are welded 3.1.2.2.11.1, and Fall 2029 when with Alloy 152 weld materials. The tubesheet cladding is Alloy 182 and the primary head Table the replacement cladding is stainless steel. There is a concern regarding potential failure at the divider plate 3.1.2-4 steam generators welds to primary head and tubesheet cladding and Callaway Ameren Missouri commits to are in service for perform one of the following three resolution options: more than 20 years.

Option 1: Inspection Perform a one-time inspection of each steam generator to assess the condition of the divider plate welds. The examination technique(s) will be capable of detecting PWSCC in the divider plate assemblies and the associated welds.

OR Option 2: Analysis Perform an analytical evaluation of the steam generator divider plate welds in order to establish a technical basis which concludes that the steam generator reactor coolant system pressure boundary is adequately maintained with the presence of steam generator divider plate weld cracking. The analytical evaluation will be submitted to the NRC for review and approval.

OR Option 3: Industry/NRC Studies If results of industry and NRC studies and operating experience document that potential failure of the steam generator reactor coolant system pressure boundary due to PWSCC cracking of steam generator divider plate welds is not a credible concern, this commitment will be revised to reflect that conclusion.

Callaway Plant Unit 1 Page A-48 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 99 of 136 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments LRA Implementatio Item # Commitment Section n Schedule 35 The material of steam generator tubesheet cladding is Alloy 182. The tubes are made of Alloy Section Between Fall 2025 690 and are secured to the tubesheet by means of tube to tubesheet leaktight weld and tube 3.1.2.2.11.2, and Fall 2029 when expansion. There is a concern regarding potential failure of primary-to-secondary pressure Table the replacement boundary due to PWSCC cracking of tube-to-tubesheet welds. Callaway Ameren Missouri 3.1.2-4 steam generators commits to perform one of the following two resolution options: are in service for Option 1: Inspection more than 20 years Perform a one-time inspection of a representative number of tube-to-tubesheet welds in each steam generator to determine if PWSCC cracking is present. The examination technique(s) will be capable of detecting PWSCC in the tube-to-tubesheet welds. If weld cracking is identified, the condition will be resolved through repair or engineering evaluation to justify continued service, as appropriate, and a periodic monitoring program will be established to perform routine tube-to-tubesheet weld inspections for the remaining life of the steam generators.

OR Option 2: Analysis Perform an analytical evaluation of the steam generator tube-to-tubesheet welds either determining that the welds are not susceptible to PWSCC, or redefining the reactor coolant pressure boundary of the tubes, where the steam generator tube-to-tubesheet welds are not required to perform a reactor coolant pressure boundary function. The redefinition of the reactor coolant pressure boundary will be submitted as part of a license amendment request requiring approval from the NRC. The evaluation for determination that the welds are not susceptible to PWSCC and do not require inspection will be submitted to the NRC for review.

Callaway Plant Unit 1 Page A-48 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 100 of 136 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments LRA Implementation Item # Commitment Section Schedule 41 To allow for monitoring of the condition of the threads on the RPV stud and flange hole B2.1.3 Completed no later threads, Callaway Ameren Missouri commits to remove RPV stud #18 through non-destructive than six months prior or destructive means. If RPV stud hole repair is required following removal of RPV stud #18, to the PEO or the the repair plan will include inspecting the RPV stud hole prior to the repair to assess the as- refueling outage prior found condition and an inspection after the repair is complete to assess the results of the to the period of repair. extended operation, whichever occurs later.

42 It is noted that Callaway Ameren Missouri experienced problems with the reactor vessel head B2.1.3 Completed no later closure studs and stud holes early in plant life (1986 - 1992), and that multiple RPV stud holes than six months prior required ASME Section XI repairs to remove damaged threads. To supplement the monitoring to the PEO or the that is accomplished through regular volumetric inspections and to confirm that additional refueling outage prior thread degradation is not occurring in the RPV stud holes, Callaway Ameren Missouri commits to the period of to perform a one-time inspection of select RPV stud holes using a method consistent with the extended operation, Babcock and Wilcox laser inspection that was applied following stud hole repair in 1989 and whichever occurs 1992. RPV stud hole locations 2, 4, 5, 7, 9, and 53 have had more than one thread removed later.

and will be inspected. If inspection of these RPV stud holes confirms that there was minimal or no additional degradation since the prior video inspection, then it is a reasonable conclusion that there will be minimal additional degradation in the period of extended operation. If additional degradation is observed in any of the repaired stud holes where more than one thread has been removed, the condition will be entered in the Corrective Action Program for evaluation and corrective action, and the remaining repaired RPV stud hole locations 13, 25, 39 and 54 will be inspected. The inspection is expected to confirm that further degradation is not occurring in the repaired stud holes, and will provide a basis for the conclusion that acceptance criteria for thread engagement will continue to be met through the period of extended operation.

Callaway Plant Unit 1 Page A-49 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 101 of 136 Appendix B AGING MANAGEMENT PROGRAMS B2.1.6 PWR Vessel Internals Program Description The PWR Vessel Internals program manages cracking, loss of material, loss of fracture toughness, change in dimension, and loss of preload for reactor vessel internal components intended to provide core structural support. The program implements the guidance of EPRI 1022863 (MRP-227-A), PWR Internals Inspection and Evaluation Guideline and EPRI 1016609 (MRP-228), Inspection Standard for PWR Internals. Applicable aging management program plant-specific action items, conditions and limitations identified in NRC Safety Evaluation for MRP-227 have been addressed in this aging management program.

The program is designed to identify cracking, loss of material induced by wear, loss of fracture toughness due to either thermal aging or neutron irradiation embrittlement, change in dimension due to void swelling and irradiation growth, distortion, or deflection, and loss of preload due to thermal and irradiation-enhanced stress relaxation or creep. The cracking mechanisms managed by this program include stress corrosion cracking (SCC), primary water stress corrosion cracking (PWSCC), irradiation-assisted stress corrosion cracking (IASCC), and cracking due to fatigue/cyclical loading.

The reactor vessel internal components are chosen for one of four inspection sample groups based on the guidance of MRP-227-A. The primary group inspections manage aging consistent with the inspection guidance of Table 4-3 (Westinghouse components) of MRP-227-A and are expected to show the leading indications of aging effects. The expansion group inspections manage aging consistent with Table 4-6 (Westinghouse components) of MRP-227-A after inspections find aging effects to be more severe than anticipated in the primary group inspections. Components in the existing program group inspections, consistent with the inspection guidance in Table 4-9 of MRP-227-A, are adequately managed by existing programs, such as ASME Code,Section XI, Examination Category B-N-3 examinations of core support structures. The fourth group consists of components for which aging effects were determined to be negligible, relative to other internals components, and no additional measures for aging management are specified.

Program examination methods include visual examination (VT-3), enhanced visual examination (EVT-1), volumetric examination, and physical measurements. Visual examinations are performed consistent with the guidance of MRP-227-A. The MRP-227-A guidance is consistent with the ASME Code Section XI rules, and includes additional guidance and methods of detecting relevant conditions. Volumetric examinations of reactor vessel internals, such as bolting, pins, and fasteners, are performed in accordance with the guidance of MRP-228 and MRP-227-A. This guidance includes requirements for the ultrasonic testing techniques used to detect loss of integrity of reactor vessel internals bolts, pins and fasteners.

Callaway Plant Unit 1 Page B-28 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 102 of 136 Integral attachments to the internal surface of the reactor vessel are managed by the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD program (B2.1.1)

Examination Category B-N-2. Bottom mounted instrumentation flux thimble tubes are managed by the Flux Thimble Tube Inspection program (B2.1.22).

The PWR Vessel Internals program is a new program that will be implemented within 24 months after the issuance of MRP-227-A, PWR Internals Inspection and Evaluation Guideline. The program will include future industry operating experience, as it is incorporated into future revisions of MRP-227-A, to provide reasonable assurance for the long-term integrity of the reactor vessel internals.

NUREG-1801 Consistency The PWR Vessel Internals program is a new an existing program that, when implemented, will be is consistent with NUREG-1801,Section XI.M16A, PWR Vessel Internals.

Exceptions to NUREG-1801 None Enhancements None Operating Experience The following discussion of operating experience provides objective evidence that the PWR Vessel Internals program will be effective in ensuring that intended functions are maintained consistent with the current licensing basis for the period of extended operation:

1. Based on industry operating experience, Callaway replaced the Alloy-750 guide tube support pins (split pins) with strained hardened (cold worked) 316 stainless steel pins during Refuel 13 (Spring 2004) to reduce the susceptibility for stress corrosion cracking in the split pins. There were no cracked Alloy X-750 pins discovered during the replacement process.

2. The ASME Code,Section XI, Examination Category B-N-3 examinations of core support structures conducted during the Refuel 13 (Spring 2004), did not identify any conditions that required repair or replacement.

3. With exception of the existing program components managed by ASME Section XI ISI, the Callaway PWR Vessel Internals program will be a new program. A key element of the program defined in MRP-227-A is the requirement to report aging effects of reactor vessel internal components. Callaway, through its participation in PWR Owners Group and EPRI-MRP activities, will continue to benefit from the industry-wide collaboration of results from internals inspections.

Callaway Plant Unit 1 Page B-29 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 103 of 136 The operating experience of the ASME Code,Section XI, Examination Category B-N-3 examinations of core support structures did not identify any significant age-related deficiencies. Occurrences that would be identified under the PWR Vessel Internals program will be evaluated to ensure there is no significant impact to safe operation of the plant and corrective actions will be taken to prevent recurrence. Guidance for re-evaluation, repair, or replacement is provided for locations where aging is found. Therefore, there is confidence that implementation of the PWR Vessel Internals program will effectively identify aging prior to loss of intended function.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

Conclusion The continued implementation of the PWR Vessel Internals program will provide reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Callaway Plant Unit 1 Page B-30 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 104 of 136 Appendix B AGING MANAGEMENT PROGRAMS B2.1.10 Open-Cycle Cooling Water System Program Description The Open-Cycle Cooling Water (OCCW) System program manages loss of material, wall thinning, reduction of heat transfer, cracking, blistering, change in color, and hardening and loss of strength for those components that are exposed to the raw water environment of the essential service water (ESW) system and heat exchangers and other components in other systems serviced by the essential service water system.

The activities for this program are consistent with the Callaway commitments to the requirements of NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Components and provide for management of aging effects in raw water cooling systems through tests, inspections and component cleaning. System and component testing, visual inspections, nondestructive examination (i.e., ultrasonic testing and eddy current testing), and biocide and chemical treatment are conducted to ensure that aging effects are managed such that system and component intended functions and integrity are maintained.

Periodic heat transfer testing or inspection and cleaning of heat exchangers with a heat transfer intended function is performed in accordance with Callaway commitments to NRC Generic Letter 89-13 to verify heat transfer capabilities.

Routine inspections and maintenance of the OCCW System program ensure that corrosion, erosion, sediment deposition and biofouling cannot degrade the performance of safety-related systems serviced by the essential service water system.

The guidelines of NRC Generic Letter 89-13 are utilized for the surveillance and control of biofouling. Procedures provide instructions and controls for biocide injection. Periodic inspections are performed for the presence of mollusks and biocide treatments are applied as necessary.

System walkdowns are performed periodically to assess the material condition of OCCW system piping and components. Compliance with the licensing basis is ensured by review of system design basis documents as well as periodic performance of self assessments.

Callaway uses internal coatings only on the component cooling water heat exchanger end bells, channels, and tubesheets; the control room air conditioner tubesheets; the class 1E electrical equipment air conditioner tubesheets; and the essential service water system strainers. This amount of coating surface area is relatively small and its aging has not been a concern for essential service water system performance.The internal coatings of components within the scope of this program are periodically visually inspected to ensure that loss of coating integrity is detected prior to (1) loss of component intended function, including loss of function due to accelerated degradation caused by localized coating failures, and (2) degradation of downstream component performance due to flow blockage.

Callaway Plant Unit 1 Page B-41 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 105 of 136 Appendix B AGING MANAGEMENT PROGRAMS Examination of polymeric materials by OCCW System program will be consistent with examinations described in the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program (B2.1.23).

The external surfaces of the buried OCCW components are managed by the Buried and Underground Piping and Tanks program (B2.1.25). The aging management of closed-cycle cooling water systems is described in B2.1.11, Closed Treated Water Systems program, and is not included as part of this program.

NUREG-1801 Consistency The Open-Cycle Cooling Water System program is an existing program that, following enhancement, will be consistent with NUREG-1801,Section XI.M20, Open-Cycle Cooling Water System.

Exceptions to NUREG-1801 None Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following program elements:

Parameters Monitored or Inspected (Element 3), Detection of Aging Effects (Element 4), and Acceptance Criteria (Element 6)

Procedures will be enhanced to include polymeric material inspection requirements, parameters monitored, and acceptance criteria. Examination of polymeric materials by OCCW System program will be consistent with examinations described in the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program (B2.1.23).

Procedures will be enhanced to include inspection and cleaning, if necessary, of the air-side of safety-related air-to-water heat exchangers cooled by essential service water.

Preventive Actions (Element 2), Parameters Monitored or Inspected (Element 3), Detection of Aging Effects (Element 4), and Acceptance Criteria (Element 6)

Procedures will be enhanced to inspect the essential service water strainers for coating degradation.

Preventive Actions (Element 2), Parameters Monitored or Inspected (Element 3), Detection of Aging Effects (Element 4), Monitoring and Trending (Element 5) and Acceptance Criteria (Element 6)

Callaway Plant Unit 1 Page B-42 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 106 of 136 Appendix B AGING MANAGEMENT PROGRAMS Procedures will be enhanced to inspect for coating detachment indications that could affect downstream components during internal coatings inspections and specify acceptance criteria for coating detachment indications. Coatings detachments that are not repaired or removed to leave sound coating bonded to the surface will be evaluated to confirm coating manufacturer installation requirements, tested using techniques identified in ASTM-D7167 to confirm if the coating is bonded to the surface, and trended.

Procedures will be enhanced to perform periodic visual inspections of the internal coatings of components within the scope of this program to ensure that loss of coating integrity is detected prior to (1) loss of component intended function, including loss of function due to accelerated degradation caused by localized coating failures, and (2) degradation of downstream component performance due to flow blockage. Inspection frequency is based on coating condition. Inspection results will be evaluated by personnel qualified consistent with ASTM D7108-05, Standard Guide for Establishing Qualifications for a Nuclear Coating Specialist, as described in the Protective Coating Monitoring and Maintenance program (B2.1.33). Acceptance criteria will include the following:

• Peeling and delaminations are not permitted.

• Cracking is not permitted if accompanied by delamination or loss of adhesion.

• Blisters are limited to intact blisters. Testing will be performed to confirm that the blisters are completely surrounded by sound coating bonded to the surface.

• Localized areas of coating degradation without subsequent loss of material of the base metal are considered acceptable if the area is completely surrounded by sound coating bonded to the surface.

Detection of Aging Effects (Element 4),

Prior to the period of extended operation, an inspection technique will be selected from available technologies to identify internal pipe wall degradation due to MIC for performance of a one-time inspection of a buried carbon steel piping segment that is representative of other accessible carbon steel ESW piping segments.

Operating Experience The following discussion of operating experience provides objective evidence that the Open-Cycle Cooling Water System program will be effective in ensuring that intended functions are maintained consistent with the current licensing basis for the period of extended operation:

Callaway Plant Unit 1 Page B-43 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 107 of 136 Appendix B AGING MANAGEMENT PROGRAMS

1. In 2000, during routine maintenance, Asiatic clams were found in an RHR room cooler, blocking approximately 15 percent of the tubes. In subsequent inspections, clams were found in several service water and essential service water heat exchangers and room coolers. It was determined that the clams originated in the waste treatment clearwell, from which they were flushed into the suction of the service water pumps. The service water pumps distributed the clams to the heat exchangers and room coolers. As corrective action, procedures were strengthened to require more frequent inspections and provide for a more robust chemistry program to control the clams. Corrective action also included plant modifications, such as installing strainers on the discharge line of the service water pumps.

2. In 2001, through-wall corrosion had been observed in the RHR pump room cooler. The exact cause could not be determined but was believed to be from microbiologically influenced corrosion attack. The cooler was repaired.

3. Performance of the containment coolers degraded over time due to debris from the service water system, so that by 2001 there was very little margin available. The design of the original containment cooler coils did not allow them to be mechanically cleaned, and flushing was ineffective. The coils for containment coolers A and B were replaced in Refuel 11 (Spring 2001), and the coils for C and D were replaced in Refuel 12 (Fall 2002). The replacement coils have a removable cover plate which permits access to mechanically clean individual tubes.

4. In 2007, Callaway revised the program so that the component cooling water heat exchangers are the only heat exchangers that are performance tested. In order to maintain heat removal capability of the other NRC Generic Letter 89-13 heat exchangers, Callaway cleans and inspects heat exchangers at regular intervals, as well as performs flow and pressure measurements according to the essential service water flow balance procedure. The inspections check for micro-fouling, and include thermographies or ultrasonic examinations of internal surfaces. These maintenance activities supplement the commitment to thermal performance testing made in response to NRC Generic Letter 89-13. The primary and additional monitoring methods have been determined for each of the NRC Generic Letter 89-13 heat exchangers, in accordance with the guidance of EPRI Technical Report 1007248, Alternative to Thermal Performance Testing and/or Tube-side Inspections of Air-to-Water Heat Exchangers.

5 In 2007 while performing UT inspections, it was discovered that the top portion of the B ESW pump discharge piping was partially eroded. Extent of condition inspections identified a similar condition on the discharge of the A ESW pump. The piping segments were replaced and added to the Raw Water monitoring program to inspect the segments for erosion.

Callaway Plant Unit 1 Page B-44 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 108 of 136 Appendix B AGING MANAGEMENT PROGRAMS

6. From 2008 to 2009, the buried portions of the ESW supply from the ESW pump house and return to the ultimate heat sink cooling tower were replaced with high-density polyethylene (HDPE) piping. In addition, sections of above ground or underground carbon steel piping that interfaces with the buried piping was replaced with stainless steel piping. These modifications were performed as a result of the material condition of the ESW system. These modifications were performed as a result of corrective action documents that have been written concerning pinhole leaks, pitting, and other localized degradation of the ESW piping system.

7. In 2009, the replacement of the emergency diesel generator jacket water heat exchangers was evaluated due to loss of material in the tubes. The evaluation determined that a better material of construction and a better design would minimize aging effects due to raw water environment in the emergency diesel generators. The replacement jacket water heat exchangers and the emergency diesel generator lube oil coolers had tubes made of AL6XN stainless steel and were replaced in Refuel 17 (Spring 2010). The emergency diesel generator intercoolers were replaced in Refuel 18 (Fall 2011), and also have tubes fabricated from AL6XN stainless steel.

8. In 2009, room cooler flow rates had been observed to be low in the RHR pump room cooler and the containment spray pump room cooler. The low flow rates were determined to be from material that was dislodged during weld repairs from the outage prior to flow testing. The coolers were flushed to remove the debris, and flow rates were restored to their normal operating condition.

9. Prior to 2010, the coils for the following safety-related room coolers were replaced due to performance or aging issues: auxiliary building north penetration room cooler, auxiliary building south penetration room cooler, component cooling water pump room cooler train A, component cooling water pump room cooler train B, and spent fuel pool room cooler A. The material for the replacement coils is AL6XN stainless steel.

Actions have been taken to address examples of recurring corrosion due to MIC identified above. Low Frequency Electromagnetic Technique (LFET) is used for screening large areas of piping to detect changes in the wall thickness of the pipe. Thinned areas found during the LFET scan are followed up with pipe wall thickness examinations. In addition to the pipe wall thickness examination, opportunistic visual inspections of the ESW system are also performed whenever the ESW system is opened for maintenance. Prior to the period of extended operation, an inspection technique will be selected from available technologies to identify internal pipe wall degradation due to MIC for performance of a one-time inspection of a buried carbon steel piping segment that is representative of other accessible carbon steel ESW piping segments.

Callaway Plant Unit 1 Page B-45 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 109 of 136 Appendix B AGING MANAGEMENT PROGRAMS The above examples provide objective evidence that the existing Open-Cycle Cooling Water System program preventive, condition, and performance monitoring activities prevent or detect aging effects. Occurrences that would be identified under the Open-Cycle Cooling Water System program will be evaluated to ensure there is no significant impact to safe operation of the plant and corrective actions will be taken to prevent recurrence. Guidance for re-evaluation, repair, or replacement is provided for locations where aging is found.

There is confidence that the continued implementation of the Open-Cycle Cooling Water System program will effectively identify aging prior to loss of intended function.

Conclusion The continued implementation of the Open-Cycle Cooling Water System program, following enhancement, will provide reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Callaway Plant Unit 1 Page B-46 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 110 of 136 Appendix B AGING MANAGEMENT PROGRAMS B2.1.13 Fire Protection Program Description The Fire Protection program manages loss of material of fire rated doors, fire dampers, and the Halon system, concrete cracking, spalling, and loss of material of fire barrier walls, ceilings, and floors, and increased hardness, shrinkage, and loss of strength of fire barrier penetration seals. The Fire Protection program is a condition and performance monitoring program comprised of tests and inspections that follow the applicable National Fire Protection Association (NFPA) recommendations.

The program requires visual inspections of not less than 10 percent of each type of penetration seal at least once per refueling cycle (18 months). The program specifies visual inspections of the fire barrier walls, ceilings and floors in structures within the scope of license renewal at a frequency of at least once per 18 months. Inspections of fire barriers include coatings and wraps. Periodic visual and functional tests are used to manage the aging effects of fire doors. The visual inspection frequency for fire doors is at least once per 18 months, and functional tests of closing mechanisms and latches for required doors is at least once per 18 months. Not less than 10 percent of the fire dampers are visually inspected at least once per 18 months.

Visual inspections of the Halon system will be performed to identify conditions of corrosion.

A functional test of the Halon system is performed every 18 months, which is in accordance with Callaway's NRC-approved fire protection program (FSAR Table 9.5.1-2, Item 4 SP).

NUREG-1801 Consistency The Fire Protection program is an existing program that, following enhancement, will be is consistent with NUREG-1801,Section XI.M26, Fire Protection.

Exceptions to NUREG-1801 None Enhancements None Prior to the period of extended operation, the following enhancements will be implemented in the following program elements:

Parameters Monitored or Inspected (Element 3), Detection of Aging Effects (Element 4),

Monitoring and Trending (Element 5), and Acceptance Criteria (Element 6)

Callaway Plant Unit 1 Page B-50 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 111 of 136 Appendix B AGING MANAGEMENT PROGRAMS Procedures will be enhanced to include visual inspections of the external surfaces of Halon fire suppression system components for excessive loss of material due to corrosion.

Operating Experience The following discussion of operating experience provides objective evidence that the Fire Protection program will be effective in ensuring that intended functions are maintained consistent with the current licensing basis for the period of extended operation.

1. Fire Barrier Penetration Seals In 2004, Callaway was notified by Wolf Creek of a concern with the seismic gap isolation seal between the auxiliary building and containment. At Callaway, 11 of the 23 seals were found to be incorrectly installed such that they did not meet a three-hour rated fire barrier. The deficient seals were repaired and a plant procedure was revised to clearly state the requirements for a three-hour rated fire barrier.

In 2009, a degraded fire barrier penetration seal was discovered, consisting of a void between the penetration seal and sleeve. The seal appeared to be loose from the sleeve, however, no leaks were identified and the seal was repaired.

2. Fire Doors Between 2002 and 2011, multiple fire door deficiencies were identified through regular inspections and preventive maintenance, including failure of door to fully close, sticky door latches and door locks, broken door latches, broken door, tight fit and rubbing between double doors, passive door unable to open, panic bar and latch not working, degraded bottom sweep, loose, missing and stripped hinge screws and doors dragging on the floor. The degraded fire doors were repaired and parts were replaced, as necessary to restore proper function of the fire doors.

3. Halon System A review of the most recent 10 years of Callaway operating experience was performed and confirmed that the operating experience discussed in NUREG-1801,Section XI.M26 for the Halon system is bounding, i.e., that there is no unique plant specific operating experience in addition to that described in NUREG-1801.

4. Fireproofing In 2005, during a fire barrier inspection, a small section of structural steel fireproofing (approximately 1 ft long) was degraded at the ceiling level of Room 3404 (Switchboard Room 4 on 2016 ft elevation of the control building). The affected area was repaired.

Callaway Plant Unit 1 Page B-51 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 112 of 136 Appendix B AGING MANAGEMENT PROGRAMS The above examples provide objective evidence that the Fire Protection program is capable of detecting and correcting aging effects associated with fire rated doors, fire dampers, fire barrier penetration seals, structural fire barriers, and Halon systems within the scope of license renewal. Occurrences that would be identified under the Fire Protection program will be evaluated to ensure there is no significant impact to safe operation of the plant and corrective actions will be taken to prevent recurrence. Guidance for re-evaluation, repair, or replacement is provided for locations where aging is found. There is confidence that the continued implementation of the Fire Protection program will effectively identify aging prior to loss of intended function.

Conclusion The continued implementation of the Fire Protection program, following enhancement, provides reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Callaway Plant Unit 1 Page B-52 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 113 of 136 Appendix B AGING MANAGEMENT PROGRAMS B2.1.14 Fire Water System Program Description The Fire Water System program manages loss of material for water-based fire protection systems consisting of aboveground, buried and underground piping, fittings, valves, fire pump casings, sprinklers, nozzles, hydrants, hose stations, standpipes and water storage tanks. Periodic fire main and hydrant inspections and flushing, sprinkler inspections, functional test, and flow tests in accordance with National Fire Protection Association (NFPA) codes and standards ensure that the water-based fire protection systems are capable of performing their intended function. The fire protection system is maintained at the required normal operating pressure and monitored such that a loss of system pressure is immediately detected and corrective actions initiated.

The Fire Water System program conducts full-flow testing and visual inspections to ensure that loss of material and flow blockage is adequately managed. This AMP applies to water-based fire protection system components, including sprinklers, nozzles, fittings, valve bodies, fire pump casings, hydrants, hose stations, standpipes, water storage tanks, and above ground, buried, and underground piping and components that are tested consistent with the 2011 Edition of National Fire Protection Association (NFPA) 25, "Inspection, Testing and Maintenance of Water-Based Fire Protection Systems", noted in Table B2.1.14-1.

Unless noted in Table B2.1.14-1, flow testing and visual inspections are performed at intervals specified in the 2011 Edition of NFPA 25.

The Fire Water System program performs a flow test of the system at least once every three years in accordance with plant procedures meeting the requirements of NFPA 25, including a yard fire loop flush and a flush of associated hydrants. A visual inspection and flow test of yard fire hydrants is performed annually in accordance with NFPA 25.

The Fire Water System program conducts flow tests through each open head spray/sprinkler nozzle in accordance with NFPA 25, to verify water flow is unobstructed. Prior to 50 years in service, the Fire Water System program requires sprinkler heads to be replaced or have representative samples submitted for field-service testing by a recognized testing laboratory in accordance with NFPA 25. The program field-service tests additional representative samples every 10 years thereafter during the period of extended operation to ensure signs of aging are detected in a timely manner.

Either sprinklers are replaced before reaching 50 years inservice or a representative sample of sprinklers from one or more sample areas is tested by using the guidance of the 2011 Edition of NFPA 25 to ensure that signs of degradation, such as corrosion, are detected in a timely manner.

Callaway Plant Unit 1 Page B-53 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 114 of 136 Appendix B AGING MANAGEMENT PROGRAMS In addition to NFPA codes and standards, portions of the water-based fire protection system that are: (a) normally dry but periodically are subject to flow (e.g., dry-pipe or preaction sprinkler system piping and valves) and (b) that cannot be drained or allow water to collect, are subjected to augmented testing or inspections. Also, portions of the system (e.g., fire service main, standpipe) are normally maintained at required operating pressure and monitored such that loss of system pressure is immediately detected and corrective actions are initiated.

Pipe wall thickness examinations are performed on fire water piping using non-intrusive techniques. Wall thickness examinations will be performed on fire water piping every three years. Each three year sample will include at least three locations for a total of 100 feet of above-ground fire water piping and be selected based on system susceptibility to corrosion or fouling and evidence of performance degradation during system flow testing or periodic flushes. The basis for the frequency is that three years is the frequency required by the FSAR for the yard fire loop flush and for the flow tests of the fire water loops. In addition, internal Internal inspections are performed on accessible exposed portions of fire water piping during plant maintenance activities. The inspections evaluate wall thickness measurements to ensure against catastrophic failure and the inner diameter of the piping as it applies to the design flow of the fire protection system. If a representative number of inspections have not been completed prior to the period of extended operation, Callaway will determine what additional inspections or examinations are required. The representative sample will be selected, based on system susceptibility to corrosion or fouling and evidence of performance degradation during system flow testing or periodic flushes. If material and environment conditions for above grade and below grade piping are similar, the results of the inspections of the internal surfaces of the above grade fire water piping can be extrapolated to evaluate the condition of the internal surfaces of the below grade fire water piping. If not, additional inspection activities will be performed to ensure that the intended function of below grade fire water piping will be maintained consistent with the current licensing basis. Pipe wall thickness examinations and internal inspections will be performed commencing after 2014 and throughout the period of extended operation.

Samples are collected for microbiologically-influenced corrosion quarterly and when fire water piping and components are opened for maintenance or are accessible. Biofouling is prevented by periodically adding treatment chemicals such as an anti-scalant, a biopenetrant, and a biostat to the fire water system annually and when monitoring indicates they should be added. The MIC Index is trended to evaluate treatment effectiveness in specific locations.

Functional tests are periodically performed on fire detectors to ensure that they are operable.

The internal coating of the fire water storage tanks will be inspected with a minimum frequency of alternating refueling outages.

Callaway Plant Unit 1 Page B-54 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 115 of 136 Appendix B AGING MANAGEMENT PROGRAMS The fire water storage tank external surfaces are inspected and volumetric examinations of the tank bottom are performed as described in the Aboveground Metallic Tanks program (B2.1.15). External surfaces of buried fire main piping are evaluated as described in the Buried and Underground Piping and Tanks program (B2.1.25).

Inspections of wetted normally dry piping segments that canot be drained or that allow water to collect begin five years before the period of extended operation. The program's remaining inspections begin during the period of extended operation.

Table B2.1.14-1 Fire Water System Aging Management NFPA 25 Component Aging Management Performed Section Sprinkler 5.2.1.1 Sprinklers are inspected for signs of leakage, corrosion, Systems: and foreign material.

Sprinkler inspections Sprinkler 5.3.1 Prior to 50 years in service, the Fire Water System Systems: program requires sprinkler heads to be replaced or have Sprinkler testing representative samples submitted for field-service testing by a recognized testing laboratory in accordance with NFPA 25. The program field-service tests additional representative samples every 10 years thereafter during the period of extended operation to ensure signs of aging are detected in a timely manner.

Standpipe and 6.3.1 Flow testing is conducted at least every five years at the Hose Systems: hydraulically most remote hose connections of each Flow Tests zone of an automatic standpipe system to verify the water supply provides the design pressure at the required flow.

Private Fire 7.3.1 Underground and exposed piping is flow tested at flows Service Mains: representative of those during a fire to determine the Underground internal condition of the piping at minimum 3-year and Exposed intervals.

Piping Private Fire 7.3.2 Hydrants are flow tested annually to ensure proper Service Mains: functioning.

Hydrants Fire Pumps: 8.3.3.7 Not applicable. Callaway's fire protection pumps do not Suction Screens have suction screens.

Callaway Plant Unit 1 Page B-55 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 116 of 136 Appendix B AGING MANAGEMENT PROGRAMS NFPA 25 Component Aging Management Performed Section Water Storage 9.2.5.5 The exterior painted surface of the fire water storage Tanks: Exterior tanks (FWSTs) is inspected annually for signs of Inspections degradation.

Water Storage 9.2.6, The interior of each FWST is inspected every other Tanks: Interior 9.2.7 refueling cycle for signs of aging. Testing of interior inspections surfaces is performed for coating integrity and tank bottom integrity when FWSTs exhibit signs of interior pitting, corrosion, or coating failure.

Valves and 13.2.5 Main drain tests are not conducted at Callaway. As an System-Wide alternative, one of the following methods is used to Testing: Main assure the reliable operation of the fire protection water Drain Test supply system.

1. The fire suppression system is fed from two or more directions such that the failure of one isolation valve will not impair the system and the long runs of pipe are flow tested under other surveillances.

OR

2. The flow path from the fire pump to the system control valve is verified on an 18-month frequency, and the following surveillances are performed with acceptable results:

• Fire water valve position verification

• Fire protection valve cycling

• Annual fire protection loop flow test

• Fire protection water system flush

• Hydrant flush

• Post indicator valve testing

• Wet pipe, deluge, and preaction system visual inspection Valves and 13.4.3.2.2 A full flow test using air or water is performed every System-Wide to refueling outage by trip testing each deluge valve to Testing: Deluge 13.4.3.2.5 verify that spray/sprinkler nozzles are unobstructed.

Valves Water Spray 10.2.1.6, Spray system strainers are inspected and cleaned every Fixed Systems: 10.2.1.7, refueling outage and after each system actuation.

Strainers 10.2.7 Callaway does not have main line strainers.

Callaway Plant Unit 1 Page B-56 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 117 of 136 Appendix B AGING MANAGEMENT PROGRAMS NFPA 25 Component Aging Management Performed Section Water Spray 10.3.4.3 A full flow test is performed every refueling cycle using Fixed Systems: air or water to verify that spray/sprinkler nozzles are Operation Test unobstructed.

Foam Water 11.2.7.1 Not applicable. Callaway does not have a foam water Sprinkler sprinkler system.

Systems:

Strainers Foam Water 11.3.2.6 Not applicable. Callaway does not have a foam water Sprinkler sprinkler system.

Systems:

Operational Test Discharge Patterns Foam Water Visual Not applicable. Callaway does not have a foam water Sprinkler inspection sprinkler system.

Systems: for Storage tanks internal corrosion Obstruction 14.2 and The internal surface of piping and branch lines is Investigation: 14.3 inspected for foreign material every five years by flushing Obstruction, wet pipe system piping. In buildings having multiple wet Internal pipe systems, every other system is inspected every five Inspection of years, and the remaining systems are inspected at the Piping next five year interval. If foreign material is found in any system in a building during the five year inspection, then all systems in the building will be inspected.

If sufficient foreign material is found to obstruct pipe or sprinklers, then an obstruction investigation is conducted. If the visual inspection detects surface irregularities that could indicate wall loss below nominal pipe wall thickness, then follow-up volumetric examinations will be performed.

NUREG-1801 Consistency The Fire Water System program is an existing program that, following enhancement, will be consistent, with exception to NUREG-1801,Section XI.M27, Fire Water System.

Callaway Plant Unit 1 Page B-57 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 118 of 136 Appendix B AGING MANAGEMENT PROGRAMS Exceptions to NUREG-1801 Program Element Affected:

Detection of Aging Effects (Element 4)

NUREG-1801 requires inspection of fire protection systems in accordance with the guidance of NFPA-25. Callaway performs power block hose station gasket inspections at least once every 18 months. The inspection interval is in accordance with the approved fire protection program, as described in FSAR Table 9.5.1 SP, Section 5.4, rather than annually as specified by NFPA-25.

NUREG-1801 requires annual testing of fire hydrant hose. Callaway hydrostatically tests fire hoses at interior fire hose stations five years from installation and at least every three years thereafter. The testing interval is in accordance with the approved fire protection program, as described in FSAR Table 9.5.1 SP, Section 5.6.

NFPA 25, Section 13.2.5, requires annual main drain tests. Main drain tests are not conducted at Callaway. Main drain testing is a potentially risk significant activity that requires the discharge of several thousand gallons of water, the disposal of which may be problematic for a nuclear plant. As an alternative, one of the following methods is used to assure the reliable operation of the fire protection water supply system.

1. The fire suppression system is fed from two or more directions such that the failure of one isolation valve will not impair the system and the long runs of pipe are flow tested under other surveillances.

OR

2. The flow path from the fire pump to the system control valve is verified on an 18-month frequency, and the following surveillances are performed with acceptable results:

• Fire water valve position verification

• Fire protection valve cycling

• Annual fire protection loop flow test

• Fire protection water system flush

• Hydrant flush

• Post indicator valve testing

• Wet pipe, deluge, and preaction system visual inspection Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following program elements:

Callaway Plant Unit 1 Page B-58 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 119 of 136 Appendix B AGING MANAGEMENT PROGRAMS Preventive Actions (Element 2)

The Fire Water Storage Tanks internal surfaces will be recoated prior to the period of extended operation.

Parameters Monitored or Inspected (Element 3) and Detection of Aging Effects (Element 4)

The Fire Water System program will be enhanced to inspect the internal surface of piping and branch lines for foreign material every five years by flushing wet pipe system piping. In buildings having multiple wet pipe systems, every other system is inspected every five years, and the remaining systems are inspected at the next five year interval. If foreign material is found in any system in a building during the five year inspection, then all systems in the building will be inspected. If sufficient foreign material is found to obstruct pipe or sprinklers, then an obstruction investigation is conducted per NFPA 25, Annex D. Visual inspections will include an inspection technique that is capable of detecting surface irregularities due to corrosion and corrosion product deposition. If the visual inspection detects surface irregularities that could indicate wall loss below nominal pipe wall thickness, then follow-up volumetric examinations will be performed.

The Fire Water System program will be enhanced to require augmented tests and inspections of water-based fire protection system components that have been wetted but are normally dry. The augmented tests and inspections are conducted as follows on piping segments that cannot be drained or that allow water to collect:

• In each five-year interval, beginning five years prior to the period of extended operation, either conduct a flow test or flush sufficient to detect potential flow blockage, or conduct a visual inspection of 100 percent of the internal surface of piping segments that cannot be drained or allow water to collect.

• A 100% baseline inspection will be performed prior to the period of extended operation.

In each five-year interval of the period of extended operation, 20 percent of the length of piping segments that cannot be drained or that allow water to collect is subject to volumetric wall thickness inspections. Measurement points will be obtained to the extent that each potential degraded condition can be identified (e.g., general corrosion, MIC).

The 20 percent of piping that is inspected in each five-year interval will be in different locations than previously inspected piping.

If the results of a 100 percent internal visual inspection are acceptable, and the segment is not subsequently wetted, no further augmented tests or inspections will be performed.

Parameters Monitored or Inspected (Element 3), Detection of Aging Effects (Element 4), and Acceptance Criteria (Element 6)

The Fire Water System program will be enhanced to include non-intrusive pipe wall thickness examinations. Wall thickness measurements will be performed on fire water Callaway Plant Unit 1 Page B-59 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 120 of 136 Appendix B AGING MANAGEMENT PROGRAMS piping every three years. Each three year sample will include at least three locations for a total of 100 feet of above-ground fire water piping, and will be selected based on system susceptibility to corrosion or fouling and evidence of performance degradation during system flow testing or periodic flushes. In addition, internal Internal inspections will be performed on accessible exposed portions of fire water piping during plant maintenance activities. When visual inspections are used to detect loss of material, the inspection technique is capable of detecting surface irregularities that could indicate wall loss to below nominal pipe wall thickness due to corrosion and corrosion product deposition. Where such irregularities are detected, follow-up volumetric wall thickness examinations are performed. Pipe wall thickness examinations and internal inspections will be performed commencing after 2014 and throughout the period of extended operation.

Detection of Aging Effects (Element 4)

The Fire Water System program will be enhanced to include annual hydrostatic testing of fire brigade hose.

The Fire Water System program will be enhanced such that prior to 50 years in service, sprinkler heads will be replaced or representative samples will be submitted for field-service testing by a recognized testing laboratory in accordance with NFPA 25. The program will field-service test additional representative samples every 10 years thereafter to ensure signs of aging are detected in a timely manner.

The Fire Water System program will be enhanced to require the inspection of the interior of the fire water storage tanks to include checking for evidence of voids beneath the floor.

The Fire Water System program will be enhanced to change the frequency of trip testing each deluge valve from every three years to every refueling outage.

The Fire Water System program will be enhanced to change the frequency of tests of spray/sprinkler nozzle discharge patterns from every three years to every refueling outage.

The Fire Water System program will be enhanced to require the following additional inspections if pitting, corrosion, or coating failure is found during the inspection of the fire water storage tanks: (1) tank coatings are evaluated using an adhesion test consistent with ASTM D 3359, Standard Test Methods for Measuring Adhesion by Tape Test; (2) dry film thickness measurements are taken at random locations to determine the overall coating thickness; (3) nondestructive ultrasonic readings are taken to evaluate the wall thickness where there is evidence of pitting or corrosion; (4) interior surfaces are spot wet-sponge tested to detect pinholes, cracks, or other compromises in the coating; (5) tank bottoms are tested for metal loss on the underside by use of ultrasonic testing where there is evidence of pitting or corrosion; (6) bottom seams are vacuum-box tested in accordance with NFPA 22, Standard for Water Tanks for Private Fire Protection.

Callaway Plant Unit 1 Page B-61 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 121 of 136 Appendix B AGING MANAGEMENT PROGRAMS Detection of Aging Effects (Element 4) and Acceptance Criteria (Element 6)

The Fire Water System program will be enhanced to include annual hydrant flow testing in accordance with NFPA 25.

Monitoring and Trending (Element 5)

The Fire Water System program will be enhanced to review and evaluate trends in flow parameters recorded during the NFPA 25 fire water flow tests.

Acceptance Criteria (Element 6)

The Fire Water System program will be enhanced to require the removal of foreign material if its presence is found during pipe inspections to obstruct pipe or sprinklers. In addition, the source of the material is determined and corrected.

Operating Experience The following discussion of operating experience provides objective evidence that the Fire Water System program will be effective in ensuring that intended functions are maintained consistent with the current licensing basis for the period of extended operation.

1. In 2005, during a surveillance test, 10 sprinkler heads had signs of corrosion or mechanical damage. Two of the sprinkler heads were replaced, and the other eight were cleaned. There have been no additional issues with the sprinkler heads since then.

2. In 2005, an alarm was triggered for fire protection loop jockey pump excessive run time and an investigation was initiated to identify the leak. The location of the leak was determined and promptly isolated from the main fire water loop. The isolation of the leak did not affect any required suppression systems. The leak was promptly repaired and the fire water piping was returned to service.

3. In 2006, a low C-factor lead to the fire water system being chemically cleaned, resulting in removal of approximately 8900 pounds of corrosion products. The cleaning was successful in keeping the system C-factor above 91.5 as required by plant procedure.

During the chemical cleaning, five leaks developed, all of which were repaired. Since that time, two additional leaks have occurred. One was due to a cracked valve, and the cause of the other is still under investigation.

Callaway Plant Unit 1 Page B-61 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 122 of 136 Appendix B AGING MANAGEMENT PROGRAMS

4. In 2007, an inspection of the train B fire water storage tank, performed in accordance with the Callaway fire water storage tank inspection procedure, identified small amounts of corrosion and mineral deposits, generally at the weld seams. An evaluation determined another application of the tank coating would be planned. In 2009, an inspection of the train B fire water storage tank identified several areas of blistering in the coating, mainly near the welds, and calcium deposits. No major delaminations were identified, and the anodes were in good shape. Minor corrosion was identified on bare metal surfaces, with no pitting. An evaluation determined that the tank internal surfaces were satisfactory. In 2011, an inspection of the train B fire water storage tank was performed. Little to no damage or degradation was found to the internal metallic surface of the tank. There was some surface roughness/pitting when compared to clean bare metal. General blistering and some local delamination of the coating were found. The blistering on the wall and most of the floor is intact, while there was heavy blistering near the welds with smaller blistering on general plate areas. Since the fire water storage tanks are cathodically protected and most of the blisters were intact, the substrate is not expected to degrade significantly by the next inspection or re-coating, and no repair to the exposed metal is necessary.

5. In 2008, an inspection of the train A fire water storage tank identified minor blistering and limestone deposits. No corrosion was found on the tank internal surface, and the tank cathodic protection was found in satisfactory condition. The internal surface of the tank was determined to be in satisfactory condition. In 2010, an inspection of the train A fire water tank identified discontinuities and delaminations of the coating. The weld at the floor to wall interface had the most pitting, and weld locations contained heavy blistering.

The adjustments on the rectifier of the cathodic protection system were found to be adequate. An evaluation determined that, since the cathodic protection system was determined to be effective, through voltage and current measurements, the substrate would not degrade excessively before the next planned inspection.

46. In 2008, during microbiological sampling of the fire water system, elevated levels of microbiologically influenced corrosion (MIC) were detected in stagnant portions of fire water pipe supplying fire water to hose stations. As a result, a new preventive maintenance task has been created to flush hose stations with a biocide.

57. In 2011, C-factor testing was performed on the main fire loop piping to check for restrictions due to corrosion and or biofouling. The testing results did not meet the acceptance criteria, indicating excessive pressure drop leading to reduced fire water flow. The testing results were called into question so with more accurate digital crystal gauges, the system was reevaluated and the results improved by 6% to 89.5, still less than the required acceptance criteria of 91.5. A functionality determination concluded that provided compensatory measures were taken, the reduced cleanliness could be fully offset so the required fire water flow rate could be achieved and maintained. As a corrective action, the acceptance criteria in Calculation KC-005 Addendum 2 have Callaway Plant Unit 1 Page B-62 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 123 of 136 Appendix B AGING MANAGEMENT PROGRAMS been modified, and the test procedure updated accordingly. These revisions provide significant margin and consider the cleanliness trends, ensuring the fire water system is capable of performing its intended function.

Actions have been taken to address examples of recurring corrosion identified above. Pipe wall thickness examinations will be performed in addition to the opportunistic visual inspections of the fire water system. Sections of the above-ground fire water piping will be tested every three years. Each three year sample will include at least three locations for a total of at least 100 feet of above-ground fire water piping, and will be selected based on system susceptibility to corrosion or fouling and evidence of performance degradation during system flow testing or periodic flushes. This sampling program will commence after 2014, ensuring that over 1000 feet of piping in 30 locations will be inspected during the following 30 years.

MIC samples are collected quarterly and when fire water piping and components are opened for maintenance or are accessible. The MIC Index is trended to evaluate treatment effectiveness in specific locations. Biofouling is prevented by adding treatment chemicals such as an anti-scalant, a biopenetrant, and a biostat to the fire water system annually and when monitoring indicates they should be added.

The above examples provide objective evidence that the existing Fire Water System program includes activities that are capable of detecting aging effects, evaluating system leakage, and initiating corrective actions. Occurrences that would be identified under the Fire Water System program will be evaluated to ensure there is no significant impact to safe operation of the plant and corrective actions will be taken to prevent recurrence. Guidance for re-evaluation, repair, or replacement is provided for locations where aging is found.

There is confidence that the continued implementation of the Fire Water System program will effectively identify aging prior to loss of intended function.

Conclusion The continued implementation of the Fire Water System program, following enhancement, provides reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Callaway Plant Unit 1 Page B-63 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 124 of 136 Appendix B AGING MANAGEMENT PROGRAMS B2.1.15 Aboveground Metallic Tanks Program Description The Aboveground Metallic Tanks program manages cracking and loss of material on the external surfaces of outdoor, aboveground metallic tanks within the scope of license renewal that are supported on concrete or soil. The program also manages cracking, blistering, and change in color of the acrylic/urethane insulation on the condensate storage tank (CST).

The program applies to the CST, and refueling water storage tank (RWST)., and the two fire water storage tanks (FWSTs). Tanks inside plant structures and protected from the outdoor environment are managed by the External Surfaces Monitoring of Mechanical Components program (B2.1.21).

The Aboveground Metallic Tanks program is a condition monitoring program that performs periodic inspections to monitor for aging effects on the external surfaces of the tank. For the carbon steel FWSTs, the program relies on the application of paint, coatings, or tank bottom edge grout as corrosion preventive measures. In addition, cathodic protection is used on the carbon steel FWSTs as a preventive measure to prevent corrosion on exposed bare metal as-left surfaces of the tanks. For the stainless steel CST and RWST, jacketed insulation with overlapping seams that prevent moisture intrusion or spray-on polyurethane foam insulation that adheres to tank surfaces are used as a corrosion preventive measure.

There are no sealants or caulkings applied at the external interfaces between the FWST, CST, and RWST and their sloped concrete or soil foundations.

This program performs visual inspections during each refueling cycle to monitor for aging of the tank wall and dome external surface paint or damage of the external surface insulation covering. A one-time inspection of twenty-five external surface locations of approximately one square foot in area will be inspected by removing insulation, with at least ten locations near the base of the tank wall and at least two locations on the dome. Removal of the tank insulation permits a sampling visual and surface examinations of the tank external surfaces to be inspected for aging confirm that environmental impacts are not present at sufficient levels to cause pitting corrosion, crevice corrosion or cracking. Insulation is removed for inspection of the tank surface if insulation damage is detected that would permit water ingress to the tank metallic surface. Painted exterior tank metallic surfaces are inspected for signs of degradation such as flaking, cracking, and peeling, to manage loss of material of the metallic surfaces.

The chemical treatments of cooling tower water do not contain chemical compounds that could cause cracking, pitting, or crevice corrosion on the external surfaces of the tanks.

Within five years of Prior to entering the period of extended operation and during each ten year period in the period of extended operation, a one-time soil surface sample near the CST and RWST will be performed. The soil surface sample and samples of residue on the top and sides of each tank will be evaluated to ensure that chlorides or other aggressive Callaway Plant Unit 1 Page B-57 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 125 of 136 Appendix B AGING MANAGEMENT PROGRAMS cooling tower water treatment chemicals are not creating an aggressive environment that would degrade the CST, RWST, or their insulation jacketing.

This program also performs one-time UT thickness measurements volumetric examinations of the bottom of the tank within five years prior to entering the period of extended operation from the internal surface, to determine the thickness of the tank bottom. The entire tank bottom will be scanned to detect loss of material. Thickness measurements will be performed on regions of the tank bottom that indicate a loss of material below nominal plate thickness. With exception of the FWSTs, tank bottom UT thickness measurements will be performed when the tank is drained and within five years of entering the period of extended operation. Tank bottom UT thickness measurements of each FWST will be performed at least once every 10 years. A soil sample is taken underneath the CST and RWST and analyzed to demonstrate that the soil is not corrosive. The soil sample is performed prior to entering the period of extended operation and during each ten-year period in the period of extended operation.

A one-time inspection consistent with the One-Time Inspection program (B2.1.18) will be performed on the inside surfaces of the CST and RWST shell, roof and bottom.

The Aboveground Metallic Tanks program is a new program that will be implemented within the five year period prior to the period of extended operation.

NUREG-1801 Consistency The Aboveground Metallic Tanks program is new program that, when implemented, will be consistent with exception to NUREG-1801,Section XI.M29, Aboveground Metallic Tanks.

Exceptions to NUREG-1801 None Program Element Affected Detection of Aging Effects (Element 4)

NUREG-1801 requires UT thickness measurements of the tank bottoms whenever the tank is drained and at least once within five years of entering the period of extended operation.

UT thickness measurements of the bottom of each FWST from the internal surface, to determine the thickness of the tank bottom will be performed at least once every ten years.

Currently the internal surface of each FWST tank bottom will be visually inspected on an alternating refueling outage frequency. UT thickness measurements may be performed sooner if required by further evaluation of the tank bottom visual inspection results. Ten year periodic UT thickness measurements, supplemented when appropriate based on Callaway Plant Unit 1 Page B-58 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 126 of 136 Appendix B AGING MANAGEMENT PROGRAMS internal visual examinations, will be effective in managing loss of material of the tank bottoms.

Enhancements None Operating Experience The following discussion of operating experience provides objective evidence that the Aboveground Metallic Tanks program will be effective in ensuring that intended functions are maintained consistent with the current licensing basis for the period of extended operation.

1. The Aboveground Metallic Tanks program is a new program for Callaway. Industry operating experience that forms the basis for this program is included in the operating experience element of the corresponding NUREG-1801, aging management program descriptions. Plant-specific operating experience was reviewed to ensure that the operating experience discussed in the NUREG-1801, aging management program is bounding, i.e., that there is no unique plant-specific operating experience in addition to that described in NUREG-1801. The Callaway Corrective Action Program was searched to determine if aging of the CST or RWST has been identified to date. In 2007, an inspection of the train B fire water storage tank, performed in accordance with the Callaway fire water storage tank inspection procedure, identified small amounts of corrosion and mineral deposits, generally at the weld seams. An evaluation determined another application of the tank coating would be planned. In 2009, an inspection of the train B fire water storage tank identified several areas of blistering in the coating, mainly near the welds, and calcium deposits. No major delaminations were identified, and the anodes were in good shape. Minor corrosion was identified on bare metal surfaces, with no pitting. An evaluation determined that the tank internal surfaces were satisfactory. In 2011, an inspection of the train B fire water storage tank was performed. Little to no damage or degradation was found to the internal metallic surface of the tank. There was some surface roughness/pitting when compared to clean bare metal. General blistering and some local delamination of the coating was found. The blistering on the wall and most of the floor is intact, while there was heavy blistering near the welds with smaller blistering on general plate areas. Since the fire water storage tanks are cathodically protected and most of the blisters were intact, the substrate is not expected to degrade significantly by the next inspection or re-coating, and no repair to the exposed metal is necessary.

Callaway Plant Unit 1 Page B-59 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 127 of 136 Appendix B AGING MANAGEMENT PROGRAMS

2. In 2008, an inspection of the train A fire water storage tank identified minor blistering and limestone deposits. No corrosion was found on the tank internal surface, and the tank cathodic protection was found in satisfactory condition. The internal surface of the tank was determined to be in satisfactory condition. In 2010, an inspection of the train A fire water tank identified discontinuities and delaminations of the coating.

The weld at the floor to wall interface had the most pitting, and weld locations contained heavy blistering. The adjustments on the rectifier of the cathodic protection system were found to be adequate. An evaluation determined that, since the cathodic protection system was determined to be effective, through voltage and current measurements, the substrate would not degrade excessively before the next planned inspection.

The above examples provide objective evidence that the new Aboveground Metallic Tanks program will be capable of detecting the aging effects associated with this program. No cracking or loss of material were identified in a search of Callaway historical information for the CST and RWST. Occurrences that would be identified under the Aboveground Metallic Tanks program will be evaluated to ensure there is no significant impact to the safe operation of the plant and corrective actions will be taken to prevent recurrence. Guidance for re-evaluation, repair, or replacement is provided for locations where aging is found. There is confidence that the implementation of the Aboveground Metallic Tanks program will effectively identify aging prior to loss of intended function.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

Conclusion The implementation of the Aboveground Metallic Tanks program will provide reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Callaway Plant Unit 1 Page B-60 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 128 of 136 Appendix B AGING MANAGEMENT PROGRAMS B2.1.17 Reactor Vessel Surveillance Program Description The Reactor Vessel Surveillance program manages loss of fracture toughness in accordance with ASTM E 185-73, and the requirements of 10 CFR 50 Appendix H. The surveillance capsules contain reactor vessel steel specimens of the limiting beltline material; and associated weld metal and weld heat affected zone metal. Current examination methods and report requirements are also controlled by commitment to ASTM E 185-82.

The program requires the evaluation of the impact of plant operating changes on the extent of reactor vessel embrittlement (i.e., Charpy upper-shelf energy and pressurized thermal shock screening criteria, and the P-T limit curves, including the effect of lower cold leg temperature or higher fluence).

The last-tested surveillance capsule removed from the reactor vessel, Capsule X, was exposed to fluences equivalent to about 54 effective full power years (EFPY), 3.33 x 1019 neutrons/cm2 based on the calculated fluence. This fluence exceeds the 60-year peak reactor vessel wall neutron fluence. Capsule results are used to demonstrate compliance with Charpy upper-shelf energy requirements in 10 CFR 50 Appendix G and pressurized thermal shock screening criteria in 10 CFR 50.61, using the methodologies in Regulatory Guide 1.99, Radiation Embrittlement of Reactor Vessel Materials, Revision

2. Capsule results are also used to revise pressure-temperature curves and project the end-of-life fluence.

Two standby capsules will be removed at exposures greater than those expected at the beltline wall at 60 years. Capsule Z was removed at 71 EFPY of equivalent exposure and is stored in the spent fuel pool for reinsertion or testing as deemed appropriate.

Capsule W will be removed at approximately 108 EFPY of equivalent exposure. This withdrawal schedule meets the ASTM E 185-82 criterion which states that capsules may be removed when the capsule neutron fluence is between one and two times the limiting fluence calculated for the vessel at the end of expected life. Any changes to the capsule withdrawal schedule, including spare capsules, must be approved by the NRC prior to implementation.

Following withdrawal of the final capsule, vessel fluence will be determined by ex-vessel dosimetry.

NUREG-1801 Consistency The Reactor Vessel Surveillance program is an existing program that, following enhancement, will be is consistent to with NUREG-1801,Section XI.M31, Reactor Vessel Surveillance.

Callaway Plant Unit 1 Page B-64 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 129 of 136 Appendix B AGING MANAGEMENT PROGRAMS Exceptions to NUREG-1801 None Enhancements None Prior to the period of extended operation, the following enhancements will be implemented in the following program elements:

Detection of Aging Effects - Element 4 Following withdrawal of the final capsule, vessel fluence will be determined by ex-vessel dosimetry.

Testing specification will be enhanced to require that pulled and tested surveillance capsules are placed in storage for future reconstitution or reinsertion unless given NRC approval to discard.

Operating Experience The following discussion of operating experience provides objective evidence that the Reactor Vessel Surveillance program will be effective in ensuring that intended functions are maintained consistent with the current licensing basis for the period of extended operation.

1. The last-tested capsule specimens in Capsule X were exposed to fluences equivalent to approximately 54 EFPY, 3.33 x 1019 neutrons/cm2 based on the calculated fluence, and satisfy the upper-shelf energy criterion and the pressurized thermal shock reference temperature screening criteria. The adjusted reference temperatures have been shown to be less than that used in the P-T limit curves, thereby demonstrating margin in the operating limits.

The operating experience of the Reactor Vessel Surveillance program did not identify an adverse trend in performance. Occurrences that would be identified under the Reactor Vessel Surveillance program will be evaluated to ensure there is no significant impact to safe operation of the plant and corrective actions will be taken to prevent recurrence.

Guidance for re-evaluation, repair, or replacement is provided for locations where aging is found. There is confidence that the continued implementation of the Reactor Vessel Surveillance program will effectively identify aging prior to loss of intended function.

Conclusion The continued implementation of the Reactor Vessel Surveillance program, following enhancement, provides reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Callaway Plant Unit 1 Page B-65 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 130 of 136 Appendix B AGING MANAGEMENT PROGRAMS B2.1.21 External Surfaces Monitoring of Mechanical Components Program Description The External Surfaces Monitoring of Mechanical Components program manages loss of material and cracking for metallic components and cracking and changes in material properties for cement board (splash panel) components. The program also manages loss of material, cracking, hardening and loss of strength for polymeric components.

Visual inspections of external surfaces will be conducted with system inspections and walkdowns of metallic components for evidence of loss of material and leakage. The inspection parameters for metallic components include material condition, which consists of evidence of corrosion, corrosion stains, material wastage, evidence of insulation damage or wetting; wear, flaking or oxide-coated surfaces; and leakage onto external surfaces. Coating degradation (e.g. cracking, flaking, and blistering) is used as an indicator of possible underlying degradation of the component. Polymer visual inspections will inspect for surface cracking, crazing, discoloration, wear, scuffing, dimensional change, exposure of internal reinforcement, and hardening/loss of strength as evidenced by loss of suppleness during manual or physical manipulation. Stainless steel monitoring will also include visual inspection for cracking when exposed to an aggressive air environment containing halides. Cement board visual inspections will inspect for loss of material or cracking that results in a loss of the components intended function.

Visual inspections of components in normally accessible locations are conducted at least every refueling outage. This frequency accommodates inspections of components that may be in locations that are normally only accessible during outages. Surfaces that are not readily visible during plant operations and refueling outages are inspected when they are made accessible and at intervals that would ensure the components intended functions are maintained. Inspection intervals for inaccessible components will be determined based on an evaluation of aging effects and their impact on intended functions observed during external surface inspections on accessible components with the same material and environment combination.

Reduced thermal insulation resistance due to moisture intrusion, associated with insulation which is jacketed, is managed by visual inspection of the condition of the jacketing when the insulation has been included in scope to reduce heat transfer from the insulated components. Outdoor insulated components, and indoor components exposed to condensation (because the in-scope component is operated below the dew point), have portions of the insulation inspected or removed to determine whether the exterior surface of the component is degrading or has the potential to degrade.

Visible evidence of degradation will be evaluated to ensure the components intended functions are maintained. Visual inspection activities will be performed by qualified personnel in accordance with site controlled procedures and processes. Deficiencies are documented and evaluated under the corrective action process.

Callaway Plant Unit 1 Page B-75 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 131 of 136 Appendix B AGING MANAGEMENT PROGRAMS The following aging management programs manage external surface aging of metallic or polymeric mechanical components outside the scope of the External Surfaces Monitoring program:

1. Boric Acid Corrosion program (B2.1.4) for components in systems near treated borated water or reactor coolant environments where boric acid corrosion may occur.

2. Buried and Underground Piping and Tanks program (B2.1.25) for buried components in buried and underground environments.

3. Aboveground Metallic Tanks program (B2.1.15) for external surfaces of outdoor, above-ground metallic tanks.

4. ASME Section XI ISI, Subsections IWB, IWC, and IWD program (B2.1.1) for Class 1, 2, and 3 pressure-retaining components and their integral attachments.

5. Fire Protection program (B2.1.13) for external surfaces of Halon system and associated components.

The External Surfaces Monitoring of Mechanical Components program is a new program that will be implemented prior to the period of extended operation.

NUREG-1801 Consistency The External Surfaces Monitoring of Mechanical Components program is a new program that, when implemented, will be consistent with NUREG-1801,Section XI.M36, External Surfaces Monitoring of Mechanical Components.

Exceptions to NUREG-1801 None Enhancements None Operating Experience The following discussion of operating experience provides objective evidence that the External Surfaces Monitoring of Mechanical Components program will be effective in ensuring that intended functions are maintained consistent with the current licensing basis for the period of extended operation.

1. The External Surfaces Monitoring of Mechanical Components program is a new program, however, external surface monitoring via system walkdown inspections are already in effect at Callaway. Routine system walkdowns are performed as part of the Plant Health and Performance Monitoring Program. The results of the walkdowns provide data for performance monitoring and trending, are an input to work Callaway Plant Unit 1 Page B-76 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 132 of 136 Appendix B AGING MANAGEMENT PROGRAMS planning and prioritization process, and are communicated in the System Health Reports and System Performance Monitoring Indicators. The walkdown inspections have been used to effectively maintain the condition of component external surfaces.

The scope of these inspections and the inspection techniques are in accordance with industry practice. A review of the plant-specific operating experience for the past 10 years showed that the Plant Health and Performance Monitoring Program has been effective in maintaining the condition of component external surfaces.

2. In 2006, cracking was found on a rubber expansion joint located between the essential service water piping and the diesel generator intercooler heat exchanger. An extent of condition review revealed cracking on the expansion joint of the opposite train. Both expansion joints were replaced. The apparent cause of the cracking was pipe misalignment. The PMs to inspect the heat exchanger tubes were revised to include an inspection of the expansion joints. During the repair, it was discovered that the spare expansion joint in the warehouse was also cracked. As a result, the shelf life of the expansion joints was decreased from 372 months to 60 months. Expansion joint storage methods were changed to require bagging to mitigate their aging effects.

3. In 2006, loss of material due pitting and general corrosion was identified on essential service water supply line piping. A piping ultrasonic test confirmed the piping met minimum wall thickness. The pipe coating was completely restored on all bare metal surfaces of this piping, up to the floor seal. Inspection of safety-related carbon steel cooling piping exposed to aggressive environments and in the vicinity of penetrations through floors, walls, and ceilings was performed to determine extent of condition. No indications of significant corrosion were found as a result of these inspections.

4. In 2006, loss of material due pitting and general corrosion was identified on piping in the pipe chase between the condensate storage tank and the auxiliary building. The piping was ultrasonically examined to determine loss of wall thickness. Piping was replaced or recoated consistent with the results of the ultrasonic examinations. The apparent cause of the corrosion was intrusion of rainwater through the equipment access hatch at ground level outside of the condensate storage tank valve house. The access panel was resealed to prevent rain water intrusion.

5. In 2008, during a mechanical maintenance pre-job walkdown, expansion joint surface cracking was found on the emergency diesel generator intercooler heat exchanger shell side inlet and outlet. The shallow surface cracking was determined to not affect the structural integrity of the joint. The expansion joints are regularly inspected and trended per established preventive maintenance activities, so no further actions were required. During inspection of additional expansion joints on the essential service water system, additional expansion joints with cracks and visible cords were found.

Expansion joints containing cracks deep enough to affect the second layer of nylon cording were replaced, since cracking of this layer questions the structural stability of the expansion joint.

Callaway Plant Unit 1 Page B-77 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 133 of 136 Appendix B AGING MANAGEMENT PROGRAMS The operating experience for the system walkdown inspections that will be incorporated into the External Surfaces Monitoring of Mechanical Components program did not show any adverse trend in performance. Occurrences that would be identified by the system walkdowns will be evaluated to ensure there is no significant impact to the safe operation of the plant and adequate corrective actions will be taken to prevent recurrence.

Appropriate guidance for re-evaluation, repair, or replacement will be provided for locations where aging is found. There is confidence that the implementation of the External Surfaces Monitoring of Mechanical Components program will effectively identify aging prior to loss of intended function.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

Conclusion The implementation of the External Surfaces Monitoring of Mechanical Components program will provide reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Callaway Plant Unit 1 Page B-78 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 134 of 136 Appendix B AGING MANAGEMENT PROGRAMS B2.1.23 Inspection of Internal Surfaces of Miscellaneous Piping and Ducting Components Program Description The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program manages cracking, loss of material, hardening and loss of strength. The program inspects internal surfaces of metallic piping, piping components, ducting, polymeric components, and other components that are exposed to plant indoor air, ventilation atmosphere, atmosphere/weather, condensation, borated water leakage, diesel exhaust, lubricating oil, and any water system environment not managed by Open-Cycle Cooling Water System (B2.1.10), Closed Treated Water System (B2.1.11), Fire Water System (B2.1.14), and Water Chemistry (B2.1.2) programs.

Internal inspections are performed opportunistically whenever the internal surfaces are made accessible, such as periodic system and component surveillance activities or maintenance activities. Visual inspections of internal surfaces of plant components are performed by qualified personnel. For certain materials, such as polymers, visual inspections will be augmented by physical manipulation of at least 10 percent of the accessible surface area or pressurization to detect hardening, loss of strength, and cracking. Volumetric evaluations are performed when appropriate for the component environment and material. Volumetric evaluations such as ultrasonic examinations are used to detect stress corrosion cracking of internal surfaces such as stainless steel components exposed to diesel exhaust.

If work opportunities are not sufficient to allow inspection of a representative sample of components, supplemental inspections are also performed. A representative sample size is 20 percent of the accessible and inaccessible component population (defined as components having the same material and environment combination) up to a maximum of 25 components. The locations and intervals for supplemental inspections are based on assessments of the likelihood of significant aging effects, derived from current industry and plant-specific operating experience.

Identified aging deficiencies are documented and evaluated by the Corrective Action Program. Acceptance criteria are established in the maintenance and surveillance procedures or are established during engineering evaluation of the degraded condition. If the inspection results are not acceptable, the condition is evaluated to determine whether the component intended function is affected, and a corrective action is implemented.

Components having the same material-environment combination with repetitive failures due to aging require a plant-specific program, unless the component material has been replaced by a material of more corrosion resistance for the environment of interest.

Callaway Plant Unit 1 Page B-81 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 135 of 136 Appendix B AGING MANAGEMENT PROGRAMS In addition, the internal coatings of the service water pump strainers are periodically visually inspected to ensure that loss of coating integrity is detected prior to (1) loss of component intended function, including loss of function due to accelerated degradation caused by localized coating failures, and (2) degradation of downstream component performance due to flow blockage.

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program is a new program that will be implemented prior to entering the period of extended operation.

NUREG-1801 Consistency The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program is a new program that, when implemented, will be consistent with exception to NUREG-1801,Section XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.

Exceptions to NUREG-1801 Program Elements Affected:

Scope of Program (Element 1), Parameters Monitored or Inspected (Element 3),

Detection of Aging Effects (Element 4), and Monitoring and Trending (Element 5)

NUREG-1801 requires a visual examination of the internal surface of components within the scope of this program. The diesel exhaust is not available for internal surface inspection, so a volumetric examination will be performed for this component. The volumetric examination is adequate for detecting loss of material (wall thinning) and cracking of piping and tubing.

Enhancements None Operating Experience The following discussion of operating experience provides objective evidence that the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program will be effective in ensuring that intended functions are maintained consistent with the current licensing basis for the period of extended operation.

Callaway Plant Unit 1 Page B-82 License Renewal Application Amendment 28

ULNRC-06057 December 20, 2013 Page 136 of 136 Appendix B AGING MANAGEMENT PROGRAMS

1. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program will be a new program at Callaway. Internal surface monitoring through visual inspections conducted during maintenance activities and surveillance testing are already in effect in Callaway. The results of the inspections provide data for performance trending, are an input to work planning and prioritization process, and are communicated in the System Health Reports and System Performance Monitoring Indicators. Plant-specific operating experience since 2000 was reviewed to ensure that the operating experience discussed in the corresponding NUREG-1801 aging management program is bounding, i.e., that there is no unique plant-specific operating experience in addition to that described in NUREG-1801. The review also showed that the Plant Health and Performance Monitoring Program had been effective in maintaining the condition of component internal surfaces.

2. In 2007, during maintenance activities, the threaded tube end plugs on the 'B' centrifugal charging pump room cooler were found to have a loss of material due to corrosion as introduced by wear and deformation to the plugs from the repeated assembly/disassembly and cleanings. None of the plugs were leaking. An evaluation determined that 125 plugs would be replaced, future inspections of the room cooler coils would include inspection of tube plugs for loss of material due to corrosion, and replacements would be determined on a case-by-case basis. Later in 2007, the 'A' containment spray pump room cooler was inspected. There was no noticeable damage to the plugs in this cooler. Additional corrective action was to ensure a continuous on-site availability of enough plugs to replace all the plugs in one room cooler.

Internal inspections conducted during maintenance activities and surveillance testing and the Plant Health and Performance Monitoring Program have been effective in maintaining the condition of component internal surfaces. Occurrences that would be identified under the Internal Surfaces in Miscellaneous Piping and Ducting Components program will be evaluated to ensure there is no significant impact to safe operation of the plant and corrective actions will be taken to prevent recurrence. Guidance for re-evaluation, repair, or replacement is provided for locations where aging is found. There is confidence that the implementation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program will effectively identify aging prior to loss of intended function.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

Conclusion The implementation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program will provide reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Callaway Plant Unit 1 Page B-83 License Renewal Application Amendment 28